This bill aims to stop companies from writing off very high pay for top earners on their taxes. It broadens who counts as a “covered” person so more highly paid people fall under the rule, not just a few named executives. It also lets the Treasury write rules to block workarounds, like running pay through pass‑through or other entities to dodge the limit .

The bill updates tax code terms to cover “applicable remuneration,” expands the definition of who is covered (including anyone providing services after December 31, 2024, plus certain past top officers from 2016–2024), adjusts which companies are treated as publicly held, and takes effect for tax years starting after December 31, 2024 .

• Who is affected: Public companies and their highly paid staff, including current service providers and certain former top officers from 2016–2024 .
• What changes: Companies will face a broader denial of tax deductions for excessive pay, with new terms in the tax code and anti‑avoidance rules (including for pass‑through arrangements) .
• When it starts: Applies to tax years beginning after December 31, 2024 .