O:LaYOLaYO0 8 C0 4.xaxd 99 1 guidance, rules, or regulations as are necessa?T to cam T 2 out the purposes of this section. 3 (f) EFFECTIVE DATE.--This section shall apply to 4 sales or exchanges occurring after December 31, 2007, in 5 taxable years ending after such date. 6 SEC. 302. SPECIAL RULES FOR TAX TREATMENT OF EXECU- 7 T1VE COMPENSATION OF EMPLOYERS PAR- 8 TICIPATING IN THE TROUBLED ASSETS RE- 9 LIEF PROGRAM. 10 (a) DENIAL OF DEDUCTION. Subsection (m) of' see- 11 tion 162 of' the Internal Revenue Code of' 1986 is amended 12 by adding at the end the following new paragraph: 13 "(5) SPECIAL RULE FOR APPLICATION TO EM- 14 PLOYERS PARTICIPATING IN THE TROUBLED ASSETS 15 RELIEF PROGRAM.. 16 "(A) IN GENERXL.--In the case of an ap- 17 plicable employer, no deduction shall be allowed 18 under this chapter-- 19 "(i) in the case of executive remunera- 20 tion for any applicable taxable year which 21 is attributable to scowices performed by a 22 covered executive during such applicable 23 taxable year, to the extent that the amount 24 of such remuneration exceeds $500,000, or
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