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The Section 4960 Excise Tax: Application to Tax-Exempt and Affiliated Taxable Entities
Wilmer Hale 
[Guidance Overview] Apr. 29, 2019
"In situations where a for-profit related organization pays the lion's share of the covered employee's remuneration, the for-profit entity could be responsible for a large portion of the excise tax.... Related organizations that are publicly traded should note that any remuneration paid to a covered employee for which a deduction is not allowed by reason of Section 162(m) is not taken into account for purposes of Section 4960."
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