States. Individuals who in fact exercise such day-to-day responsibilities shall be treated as executive officers and senior management regardless of their title. 3. Special rules for tax treatment of executive compensation for employers participating in certain coronavirus relief programs (a) In general Section 162(m) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (7) Special rule for application to employers participating in certain coronavirus relief programs (A) In general In the case of an applicable employer, no deduction shall be allowed under this chapter— (i) in the case of applicable remuneration for any applicable taxable year which is attributable to services performed by a covered individual during such applicable taxable year, to the extent that the amount of such remuneration exceeds $500,000, or (ii) in the case of deferred deduction remuneration for any taxable year for services performed during any applicable taxable year by a covered individual, to the extent that the amount of such remuneration exceeds $500,000 reduced (but not below zero) by the sum of— (I) the applicable remuneration for such applicable taxable year, plus (II) the portion of the deferred deduction remuneration for such services which was taken into account under this clause in a preceding taxable year. (B) Applicable employer For purposes of this paragraph— (i) In general The term applicable employer means any employer from whom one or more assets are purchased or guaranteed in accordance with section 2 of the Protecting Taxpayer's Return on Investment Act of 2020 . (ii) Aggregation rules Two or more persons who are treated as a single employer under subsection (b) or (c) of section 414 shall be treated as a single employer, except that in applying section 1563(a) for purposes of either such subsection, paragraphs (2) and (3) thereof shall be disregarded. (C) Applicable taxable year For purposes of this paragraph, the term applicable taxable year means, with respect to any