
Section 162(m) and the $1 Million Cap: Why Your Covered Employee List Is About to Get a Lot Longer in 2026
Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.










