Summaries of Excess Remuneration Excise Tax (IRC 4960) Final Regulations

With the new year came final regulations under section 4960, interpreting the excise tax on excess remuneration paid by tax-exempt organizations to covered employees. They are effective for tax years beginning after December 31, 2021; before then, exempt organizations may rely either on Notice 2019-09 or the proposed regulations instead, but only if they do so in their entirety. Numerous commentators have now created helpful summaries of the final rules, including:

• Law Firms
  • Ropes & Gray (a detailed summary)
  • Steptoe (highlighting changes from the proposed regulations)

• Accounting Firms
  • Deloitte (a particularly detailed summary)
  • EY
  • Grant Thornton (a particularly detailed summary)
  • KPMG
  • PWC (highlighting changes from the proposed regulations)

• Media Outlets
  • Bloomberg (highlighting changes from the proposed regulations)
  • National Law Review (a particularly detailed summary)

Lloyd Mayer