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These proposed regulations provide guidance under 162(m). Section 162(m)(1) generally limits the allowable deduction for a taxable year for applicable employee remuneration by any publicly held corporation paid with respect to a covered employee. Section 162(m) was amended by the American Rescue Plan Act of 2021 (Act) (Pub. L. 117-2, 135Stat.206 (2021)). The Act amended the definition of covered employee. Proposed regulations on this amendment were issued on January 16, 2025 (90 FR 4691).  The proposed regulations will be re-proposed with proposed regulations implementing the amendment to section 162(m) made by the One Big Beautiful Bill Act (OBBBA) (Pub. L. No. 119-21, 139 Stat. 72 (2025)). OBBBA amended section 162(m) by adding a rule concerning remuneration paid by members of a controlled group. The proposed regulations will provide guidance for this amendment.