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View More American Law Institute Continuing Legal Education Group [ALI CLE] Webcasts and Conferences

New Proposed Section 4960 Regulations: What Tax-Exempt Employers Need to Know

American Law Institute Continuing Legal Education Group [ALI CLE]

July 7, 2020
12:00 p.m. - 1:30 p.m. ET
Webcast

On June 5, 2020, the IRS and Treasury Department released long-awaited proposed regulations under IRC § 4960 (originally enacted in late 2017 as part of the Tax Cuts and Jobs Act). These regulations provide tax-exempt and related organizations with guidance on how to calculate the excise tax for remuneration paid in excess of $1 million and for any excess parachute payment to a “covered” employee.

If you represent tax-exempt organizations with high-level executives, or public companies with tax-exempt affiliates or foundations, you need to understand who is considered to be a covered employee and a related organization, as well as how these new tax payments will work.

This 90 minute webcast will:

  • Discuss how the proposed regulations apply to factual situations your clients may present
  • Explain how the proposed regulations differ from the prior Notice 2019-09
  • Provide insights as to how these impact for-profit employers who are related to tax-exempt entities
  • Look at how these proposed regulations impact compensation committees

Featuring a faculty of two attorneys in the IRS’s Exempt Organizations and Employment Taxes Division involved in developing the proposed regulations, as well as two highly-experienced private practitioners, this webcast will discuss:

  • How this tax applies to affiliated taxable entities (ATEO)
  • Whether the tax can be addressed in affiliated entities by donating services
  • How to calculate the remuneration considered in the annual remuneration tax
  • How you know what the parachute payment tax will apply to in employee separations from service
  • Determining who is a covered employee of an ATEO
  • How the tax impacts tax exempt affiliates of publicly traded companies and what relief is under the proposed regulations
  • Which guidance a taxpayer can rely upon in calculating the tax under §4960
  • With the comment period closing on August 10, now is the time to make sure you understand these proposed rules.

All registrants will receive a set of downloadable course materials to accompany the program.

Faculty:

  • Greta E. Cowart, Partner, Jackson Walker LLP, (Planning Chair)
  • M.J. (Mike) Asensio, Baker & Hostetler LLP
  • William L. McNally, Attorney, Employee Benefits, Exempt Organizations and Employment Taxes Division, Office of the Chief Counsel, Internal Revenue Service
  • Stephen B. Tackney, Deputy Associate Chief Counsel, Employee Benefits, Exempt Organizations and Employment Taxes Division, Office of the Chief Counsel, Internal Revenue Service

More Information, How to Register

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