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Updated Glass Lewis Proxy Voting Guidelines (Clawbacks)

Snell & Wilmer Benefits

I previously blogged about the New York Stock Exchange and Nasdaq listing standards that require issuers to adopt compliant clawback policies by December 1, 2023.

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Option Grant Practices: A Trap for the Unwary – Spring-Loading and Bullet-Dodging

Proskauer's Employee Benefits & Executive Compensa

120 , explaining how companies should properly recognize and disclose compensation cost for spring-loaded awards. Companies that have allegedly engaged in spring-loading or bullet-dodging have been the subject of SEC investigations as recently as a few years ago.

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Tax Court Decision Interprets Profits Interest “Safe Harbor” under IRS Rev. Proc. 93-27

Proskauer's Employee Benefits & Executive Compensa

The Tax Court’s May 3, 2023, decision in ES NPA Holding, LLC v. Commissioner (T.C. The Tax Court further stated that “[it does] not view Revenue Procedure 93‑27 in such a restricted manner, but rather view[s] [Revenue Procedure 93‑27] as administrative guidance on the treatment of the receipt of a partnership profits interest for services.”

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