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IRS Issues Guidance on New Excise Tax on Excess Compensation Paid by Not-for-Profit Entities
Buck [Guidance Overview] Feb. 20, 2019
"The [JCT] Explanation indicates that Congress intended to apply the excise tax to state colleges and universities (and thus highly paid athletic directors and coaches), but a technical correction may be necessary to reflect this intent. Notice 2019-09 does not make this assumption.... The same rules that apply in determining a related entity for reporting on Form 990 apply here.... While remuneration from the related entities is aggregated, each tax-exempt entity in a control group has its own covered employees."
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