This bill significantly expands the existing tax code provision, Section 162(m), which denies corporate tax deductions for excessive executive compensation. Its primary goal is to broaden the scope of individuals and companies subject to these limits, thereby reducing the tax subsidy for high-value remuneration. The legislation redefines "applicable employee remuneration" as "applicable remuneration" and "covered employee" as "covered individual," indicating a wider application of the deduction denial. A central change is the expanded definition of a "covered individual" to include any individual performing services for a taxpayer in taxable years beginning after 2024. This status also becomes permanent for individuals who were previously principal executive or financial officers, or among the three highest-compensated officers, in certain prior taxable years. Additionally, the bill modifies the definition of a "publicly held corporation" to encompass those required to file reports under Section 15(d) of the Securities Exchange Act at any point during the preceding three-year period, extending the reach of the deduction limits. To ensure the effectiveness of these changes, the bill grants the Secretary of the Treasury new regulatory authority. This authority allows for the issuance of guidance and rules necessary to prevent avoidance of the limits, including through pass-through or other entities. These amendments are slated to apply to taxable years beginning after December 31, 2024.