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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 Tax Cuts and Jobs Act (signed into law in late 2017) added Section 4960 to the Internal Revenue Code (“Code”). Code Section 4960 imposes an excise tax (currently 21 percent) on certain excess executive compensation paid...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
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
As part of 2017’s Tax Cuts and Jobs Act, Congress added new Section 4960 to the Internal Revenue Code. Section 4960 imposes an excise tax — currently set at 21 percent — on “applicable tax-exempt organizations” that pay...more
Just in time for the New Year and notwithstanding the government shutdown, on December 31, 2018, the Internal Revenue Service (“IRS”) issued Notice 2019-09 (the “Notice”), which provides interim guidance on the new excise tax...more
The Tax Cuts and Jobs Act of 2017 imposes excise taxes on tax-exempt organizations who pay compensation excess of $1 million or make certain “excess parachute” payments on account of termination of employment. ...more
Tax-exempt organizations may be surprised to learn of the practical impact of a statute enacted as part of the Tax Cuts and Jobs Act in December 2017. Section 4960 of the Internal Revenue Code immediately put in place...more
The 2017 Tax Cut and Jobs Act, signed into law on December 22, 2017, added Internal Revenue Code section 4960, which imposes a 21% excise tax on annual compensation in excess of $1 million paid by an “applicable tax-exempt...more
The 2017 Tax Cut and Jobs Act,signed into law on December 22, 2017, added Internal Revenue Code section 4960, which imposes a 21% excise tax on annual compensation in excess of $1 million paid by an “applicable tax-exempt...more
As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act (the “Act”), signed into law at the end of 2017, contains significant changes affecting the tax treatment of certain fringe benefits and executive...more
Late last year, Congress passed the Tax Cuts and Jobs Act (the “Act”) and it was quickly signed by the President. The Act seeks to reform the current tax system and contains numerous provisions that may be significant to...more
On December 20, 2017, Congress passed its comprehensive tax reform bill, the Tax Cuts and Jobs Act (the “Act”), which was signed into law by President Trump on December 22, 2017. The Bill represents one of the most extensive...more
The new tax law brought an unpleasant surprise for many tax-exempt organizations by imposing a 21 percent excise tax on compensation in excess of $1 million and on certain ‘‘parachute payments.’’ Organizations, including...more
Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more
Deferred compensation arrangements maintained by tax-exempt organizations must already comply with certain provisions of the Internal Revenue Code of 1986, as amended (“Code”), including the deferred compensation rules under...more
On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (H.R. 1), or the "Act," a comprehensive tax reform package representing an overhaul of federal taxation arguably ona level not seen in more than...more
After a short period of deliberations by the House of Representatives (the “House”) and the Senate, President Trump signed the final version of H.R. 1 into Public Law No. 115-97 on December 22, 2017 (the “New Law”). The New...more
On December 22, 2017, President Trump signed into law a tax bill reconciling both the House and Senate versions of the so-called Tax Cuts and Jobs Act. The Act’s major provisions are lowering the corporate tax rate to 21%...more
As we are sure you know, H.R. 1, informally known as the Tax Cut and Jobs Act, became law on December 22, 2017. This new law will impact almost all taxpayers. Ballard Spahr's Tax Group has prepared a detailed summary of...more
The Tax Cuts and Jobs Act, signed into law by President Donald J. Trump shortly before Christmas, is the most significant tax reform legislation in more than 30 years. ...more
The “intermediate sanctions” rules under Section 4958 of the Internal Revenue Code have long governed the payment of compensation to executives of public charities. While these rules are highly prescriptive, if followed, they...more