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Internal Revenue Code section 162(m) limits tax deductibility of executive compensation to $1 million per covered executive, with an exception for performance-based compensation. Both stock options and annual bonuses can qualify as performance-based, but they vary in the difficulty of qualification and the degree of additional compensation risk that qualification imposes on the executive. Most stock-option grants easily qualify with little change in risk, but qualification increases the risk associated with annual bonus compensation relative to what it was prior. The results of this study show that the propensity to issue stock options has increased for affected executives as a percentage of total compensa- tion. Additional analysis suggests that this. | ADVANCES IN TAXATION Series Editor Suzanne Luttman Recent Volumes Volumes 1-3 Edited by Sally M. Jones Volumes 4 and 5 Edited by Jerold J. Stern Volumes 6-13 Edited by Thomas M. Porcano Volume 14 Edited by Thomas M. Porcano Volumes 15 and 16 Edited by Thomas M. Porcano Volume 17 Edited by Suzanne Luttman ADVANCES IN TAXATION VOLUME 18 ADVANCES IN TAXATION EDITED BY SUZANNE LUTTMAN Department of Accounting Santa Clara University CA USA JAI United Kingdom - North America - Japan India - Malaysia - China EDITORIAL BOARD Kenneth E. Anderson University of Tennessee Caroline K. Craig Illinois State University Anthony P. Curatola Drexel University Ted D. Englebrecht Louisiana Tech University Philip J. Harmelink University of New Orleans D. John Hasseldine University of Nottingham Peggy A. Hite Indiana University-Bloomington Beth B. Kern Indiana University-South Bend Suzanne M. Luttman Santa Clara University Gary McGill University of Florida Janet A. Meade University of Houston Michael L. Roberts University of Colorado-Denver David Ryan Temple University Dan L. Schisler East Carolina University Toby Stock Ohio University .