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Top Takeaways for Tax-Exempts from IRS Guidance on Executive Compensation
McDermott Will & Emery Link to more items from this source
[Guidance Overview]
Jan. 4, 2019
"Multiple employers within a tax-exempt system can each be separately subject to the excise tax.... Employees earning significantly less than $1 million can be covered employees and covered employee status never ends.... The determination of who is a covered employee is complicated.... Multiple entities within a tax-exempt system may be liable for a portion of the excise tax.... The excise tax can apply to governmental entities.... The excise tax is determined based on the calendar year.... Payments made upon separation from service that are less than $1 million can be subject to the excise tax."

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