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Interim Guidance on Section 4960 Excise Tax Allocations: Considerations for Tax-Exempt Healthcare Organizations

The Tax Cuts and Jobs Act of 2017 (TCJA) adds Section 4960 to the Internal Revenue Code (IRC). Section 4960 imposes an excise tax for remuneration paid by an applicable tax-exempt organization (ATEO) to any covered employee in excess of $1 million plus any excess parachute payment paid by such organization to any covered employee.