New section 4960 imposes a 21% excise tax on certain organizations not subject to income tax, including organizations exempt under section 501(c)(3) and those for which income is excluded from taxation under section 115(1), if any of their five highest paid employees have annual compensation above $1 million. (It also imposes the tax on “excess parachute payments,” as defined in the statute.) In December, 2017, I wrote a blog post on “Medium: Whatever Source Derived,” arguing that, whatever the Congressional intent, the language of the statute did not reach states, their political subdivisions or integral parts of either.In particular, the post contrasted the basis of income tax exemption for states and their political subdivision to entities that fall under section 115(1). Section 115(1) excludes from gross income “income derived from...the exercise of essential governmental function and accruing to a state or any political subdivision thereof.” This provision, however,...
| # | Наименование новости | Тональность | Информативность | Дата публикации |
|---|---|---|---|---|
| 1 | Once and Future Gift Taxation of Transfers to Section 501(c)(4) Organizations: Current Law, Constitutional Issues, and Policy Considerations | 0 | 4.1 | 07-10-2026 |
| 2 | An Overview of Tax Issues for Religious Congregations | 0 | 6.08 | 07-10-2026 |
| 3 | UBIT to the Defense! ESOPs and Government Entities | 0 | 6.05 | 08-10-2026 |
| 4 | Americans for Prosperity and the Future of Schedule B | 0 | 7.07 | 08-10-2026 |
| 5 | Why the IRS Should Want to Develop Rules Regarding Charities and Politics | 0 | 5.3 | 07-10-2026 |
| 6 | Amending the Johnson Amendment in the Age of Cheap Speech | 0 | 6.3 | 07-10-2026 |
| 7 | Tax Exemption is Not a Subsidy - Except When it is | 0 | 5.43 | 07-10-2026 |
| 8 | The Section 527 Obstacle to Meaningful Section 501(c)(4) Regulation | 0 | 6.83 | 07-10-2026 |
| 9 | Legal Defense Funds as Political Organizations | 0 | 6.18 | 07-10-2026 |
| 10 | A Primer on Political Activity by 501(c) and 527 Organizations | 0 | 7.29 | 08-10-2026 |