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Notice 2019-09 and FICA

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In thinking about a standard non-qualified SERP plan for a tax-exempt organization (a nonaccount balance plan), would the remuneration under Notice 2019-09 be the same as for FICA purposes?  In general, it seems they would be the same.  Thanks in advance!

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Q–13: When is remuneration treated as paid for purposes of section 4960(a)(1)?

A–13: (a) General rule. For purposes of section 4960(a)(1), remuneration is paid for a taxable year if it is paid during the calendar year ending with or within the employer’s taxable year. Remuneration is treated as paid on the first date that the right to the remuneration is not subject to a substantial risk of forfeiture within the meaning of section 457(f)(3)(B) (regardless of whether the arrangement under which the amount is or will be paid is subject to section 457(f) or section 409A). An amount of remuneration is subject to a substantial risk of forfeiture if the right to the remuneration would be treated as subject to a substantial risk of forfeiture under Prop. Treas. Reg. § 1.457-12(e)(1). In general, this means that the amount is subject to a substantial risk of forfeiture only if entitlement to the amount is conditioned on the future performance of substantial services, or upon the occurrence of a condition that is related to a purpose of the remuneration if the possibility of forfeiture is substantial. See Prop. Treas. Reg. § 1.457-12(e)(1) for further guidance on the application of this standard.5 For purposes of this notice, remuneration that is no longer subject to a substantial risk of forfeiture is referred to as "vested" remuneration and the lapsing of a substantial risk of forfeiture is referred to as "vesting."

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Thanks.  I was trying to leverage present values we already calculate and thought the present values determined for FICA purposes were better than those determined for 990 Schedule J purposes.

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I finally read the entire Notice, and I now believe remuneration for 2018 is the present value (as of 12/31/2018) of the 2018 accrual - plus - earnings (in this case interest) on the 1/1/2018 present value.  As such, this approach now matches how I think the 990 Schedule J calculation should be done, and differs from the calculation for FICA purposes (which is only the present value of the 2018 accrual).  Does anyone agree with this approach, or have additional thoughts?

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Bumping this, as more people probably have looked at this since January.

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