of 1996, Section 280G of the Internal Revenue Code denies a corporation a deduction for any excess "parachute payment" made to a departing employee, and Section 4999 imposes on the recipient a nondeductible 20% excise tax, in addition to regular income and Social Security taxes. The 2010 United States Dodd-Frank Act includes in its provisions a mandate for shareholder votes on any future adoption of a golden parachute by publicly traded firms. In Switzerland, a referendum which "would give shareholders the power to veto executive pay plans, including golden parachutes" was put to a vote on March 3, 2013. Voters approved measures limiting CEO pay and outlawing golden parachutes. Studies and reports One study found golden parachutes associated with an increased likelihood of either receiving an acquisition offer or being acquired, a lower premium (in share price) in case of an acquisition, and higher (unconditional) expected acquisition premiums. It found firms adopting golden parachutes have lower market value compared to assets of the company and that their value continues to decline during and after adopting golden parachutes. "Gratuitous" payments made to CEOs on agreeing to have their companies acquired (i.e. payments made to CEOs by the acquiring company not mandated under the CEO's contract at the time the company is acquired) have been criticized. A "prominent" mergers and acquisitions lawyer told the New York Times that "I have had a number of situations where we've gone to management looking to do a deal and been stopped at the door until a compensation arrangement was signed, sealed, and delivered." Another lawyer told the Times: "Publicly, we have to call these things retention bonuses. Privately, sometimes it's the only way we would have got the deal done. It's a kickback." A study investigating acquirer-paid sweeteners at 311 large-firm acquisitions completed between 1995 and 1997 found that CEOs of the acquired companies accept lower acquisition premiums when the acquirer promised them a high-ranking managerial post after the acquisition. Golden parachutes are often viewed as excessive due to the substantial payouts given to senior management after an acquisition. This is further seen as excessive because other stakeholders during these acquisitions can be subject to layoffs. Golden parachutes can preserve a firms value for all stakeholders and are set in place to protect CEO’s during potential takeover situations. On June 24, 2013, The Wall Street Journal reported that McKesson Corporation chairman and CEO John Hammergren's