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New Rules for Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations
EisnerAmper 
[Guidance Overview] Aug. 27, 2020 "[C]larifications in these proposed regulations [include]: [1] A foreign organization that, for its taxable year, receives substantially all of its support (other than gross investment income) from the date of its creation from sources outside of the United States is not an ATEO. [2] Amounts includible in gross income as compensation under IRC Sec. 7872 and related regulations are included in remuneration for purposes of computing the excess compensation." |
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