Comments Due to NAFCU: IRS - Tax on Excess Tax-Exempt Organization Executive Compensation
NAFCU would like to highlight the following:
- Credit unions, or applicable tax-exempt organizations (ATEOs) may be required to pay an excise tax on the top five highest-compensated employees on excess remuneration greater than $1 million or excess parachute payments in an applicable tax year.
- Nonqualified deferred compensation plans that existed before section 4960 are not exempt from section 4960’s requirements, but remuneration paid before section 4960’s effective date—for taxable years beginning after December 31, 2017—are not subject to the excise tax.
- The proposal does not adopt a grandfathering provision for nonqualified deferred compensation contracts entered into on or before November 2, 2017.
Comments due to NAFCU: August 7, 2020
Comments due to IRS: Auguest 10, 2020
NAFCU will send comments on behalf of its members to the IRS by their deadline (August 7, 2020).