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Long Time Coming: SEC Adopts Final Dodd-Frank Clawback Rules

Proskauer's Employee Benefits & Executive Compensa

before reduction for withholding and other deductions); covers incentive-based compensation received by current and former executive officers (regardless of whether the officer engaged in any misconduct and regardless of fault), within a three-year “recovery period.”.

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AMERICAN RESCUE PLAN ACT CONTAINS MANY EMPLOYEE BENEFITS RELATED PROVISIONS

Benefits Notes

While employers (for self-insured plans and multi-employer plans) or insurance carriers (for fully insured plans) are responsible for the COBRA subsidy, the paying entity is entitled to take a federal tax credit against payroll taxes.