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Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and this episode is a "refresh" of episode 32, recorded in March 2023. It covers the Internal Revenue Code sections pertinent to business...more
When considering compensation and benefits packages to lure and retain top executives or talent, nonprofit organizations, including universities and hospitals, are often at a disadvantage compared to their for-profit rivals....more
This Freeman Law Insights blog provides an overview of the excess benefit transaction rules of 26 U.S.C. § 4958 and corresponding Treasury Regulations, 26 C.F.R. § 4958-1, et. seq....more
For high-profile athletes commanding mega salaries and worldwide fame, giving back generously to their communities or to a cherished cause is a go-to play. Charitable giving carries limited risk while offering significant...more
Proposed Regulations under Section 4960 of the Internal Revenue Code provide important guidance for tax-exempt organizations and their affiliates regarding an excise tax on certain executive compensation. The U.S. Department...more
Proposed Regulations published by the Treasury Department last month provide helpful clarifications regarding the application of the excise tax under Section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”)....more
The Treasury Department (the “Department”) and Internal Revenue Service (“IRS”) recently released detailed proposed rules (the “Proposed Regulations”) interpreting Section 4960 of the Internal Revenue Code (the “Code”). 85...more
The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more
Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more
The US Department of the Treasury has released long-expected proposed regulations regarding the section 4960 excise tax on certain remuneration or separation amounts paid to the five highest paid employees of a tax-exempt...more
The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more
On December 20, 2019, President Trump signed into law changes to the private foundation excise tax on net investment income under Section 4940 of the Internal Revenue Code. For purposes of Section 4940, net investment...more
Just in time for the holidays, Congress gave two gifts to tax-exempt organizations as part of the new government funding bill signed into law on December 20, 2019....more
As an update on an important matter that we raised during McDermott’s May 8 Tax Symposium, it is critical to promptly assess whether to report any excise taxes imposed under Section 4960 as the deadline for filing Form 4720...more
Companies that have a private foundation (or are otherwise related to a tax-exempt organization) should take immediate action to determine whether they owe an excise tax under new section 4960 of the Internal Revenue Code....more
Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more
The Tax Cuts and Jobs Act of 2017 added several new provisions to the Internal Revenue Code (the “Code”) which impose new excise taxes on tax-exempt entities. One of these new provisions is Code Section 4960, Tax on Excess...more
When it’s time for tax-exempt organizations such as colleges/universities, museums, and hospital systems to part ways with their senior executives, these institutions are most often considering how to best transition these...more
IRS Notice 2019-09 provides guidance intended to help “applicable tax-exempt employers” determine whether compensation paid to their most highly compensated employees will be subject to the 21 percent excise tax imposed under...more
Attention tax-exempt entity employers: Starting with tax filings this year (for your taxable year that began in 2018), you will need to make a special report to the IRS and pay an excise tax if you provided certain current or...more
In simplified terms, Section 4960 of the Internal Revenue Code now includes a new excise tax (currently at a 21 percent rate) on wages in excess of $1 million in a year paid or treated as paid to a "covered employee."...more
As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more
• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more
On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more