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Section 4960 imposes an excise tax on remuneration in excess of $1 million and excess parachute payments paid by an applicable tax-exempt organization (and its related organization(s)) to a covered employee. These regulations explain how to determine the amount of remuneration paid, whether there is an excess parachute payment, what is an excess parachute payment, what is an applicable tax-exempt organization, what is a related organization, and how to determine an organization’s covered employees, and how to report and pay the tax. REG-122345-18. Published January 19, 2021.
26 CFR 53.4960-0 through 53.4960-6
This notice provides additional relief under section 7508A of the Internal Revenue Code (Code) for qualified opportunity funds (QOFs) and their investors in response to the ongoing Coronavirus Disease 2019 (COVID-19) pandemic. This notice also provides additional relief pursuant to section 1400Z-2(f)(3) and Income Tax Regulations under section 1400Z-2 of the Code (section 1400Z-2 regulations). Specifically, this notice extends the relief for QOFs and their investors provided by Notice 2020-39, 2020-26 I.R.B. 984.
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