Steven Einhorn
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On December 31, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2019-09 (the “Notice”), which provides interim guidance under Section 4960 of the Internal Revenue Code. Very generally, Section 4960 imposes a 21% excise tax on certain tax-exempt entities (and certain related organizations) that pay remuneration in … Continue Reading
Last week, the IRS released Notice 2018-95 to provide transition relief to 403(b) plans that improperly excluded certain employees. Specifically, Notice 2018-95 targets employers that may have erroneously excluded part-time employees from eligibility to make elective deferral when the employees should have been eligible to participate under the “once-in-always-in” requirement (“OIAI”). According to the OIAI … Continue Reading
On February 23rd, the IRS issued a memorandum to its examiners instructing them not to challenge a 403(b) plan for failing to satisfy the required minimum distribution (“RMD”) rules with respect to missing participants or beneficiaries if the plan sponsor has taken certain specific steps to find them. Generally, the RMD rules require that a … Continue Reading
Early on December 2, 2017, the Senate passed the Tax Cuts and Jobs Act (the “Senate Bill”). This blog entry describes certain provisions of the Senate Bill that would have the most significant impact on the nonprofit community, including important differences between the Senate Bill and the prior version of the Senate bill and the … Continue Reading
Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress.[1] On Thursday, a detailed summary of the Senate Finance Committee’s proposal was released (the “Senate Markup”),[2] and the House Ways and Means Committee voted (in a 24-16, party-line vote) to … Continue Reading
House Republican Tax Bill Imposes Excise Tax on Wealthy Private Universities and Excess Compensation of Highly Paid Employees; Subjects State Pension Plans to UBTI Rules On Thursday, November 2, House Republicans led by Speaker Paul Brady (R-WI) and Chairman of the House Ways & Means Committee Kevin Brady (R-TX), released the first public draft of … Continue Reading
The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below, this means that a sponsor of a Code Section 403(b) plan who timely adopted a Code Section 403(b) retirement plan document … Continue Reading
On June 21, 2016, the Internal Revenue Service (IRS) issued anticipated proposed Treasury Regulations prescribing rules under Section 457 of the Internal Revenue Code for the income taxation of deferred compensation arrangements for employees of tax-exempt organizations and state and local governments. The IRS also released new proposed Treasury Regulations under Code Section 409A.… Continue Reading
IRS Releases Interim Guidance on New Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations
By Steven Einhorn, Tyler Forni, David Miller, Amanda H. Nussbaum and Ira G. Bogner on Posted in IRS, Tax-Exempt Organizations
IRS Announces Relief from the “Once-In-Always-In” Requirement for Excluding Part-Time Employees Under 403(b) Plans
By Steven Einhorn and Caroline Cima on Posted in IRS
IRS Provides Guidance on Searching for Missing 403(b) Participants
By Steven Einhorn on Posted in IRS
Updates for Tax-Exempt Organizations from the Senate Bill
By David Miller, Amanda H. Nussbaum, Elizabeth M. Mills, Steven Einhorn and Amy Zelcer on Posted in IRS
Updates for Tax-Exempt Organizations from the Senate Markup to the Tax Cuts and Jobs Act
By Amanda H. Nussbaum, Elizabeth M. Mills, Steven Einhorn and Amy Zelcer on Posted in Uncategorized
New Rules for Tax-Exempt Organizations in the Tax Cuts and Jobs Act
By Steven Einhorn, David Miller, Elizabeth M. Mills and Kathleen R Semanski on Posted in Charitable Giving, Private Foundations, Religious Organizations
IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans
By Steven Einhorn on Posted in IRS
Deferred Compensation for Tax-exempt Organizations: New Proposed Regulations under Code Section 457
By Michael Sirkin and Steven Einhorn on Posted in IRS, IRS Filings
