As we previously reported, under the Tax Cuts and Jobs Act, starting in 2018, tax-exempt organizations are subject to a 21% excise tax on (i) remuneration exceeding $1 million paid to a “covered employee” in a tax year, and (ii) any “excess parachute payment” paid to a covered employee.  The IRS has recently published Notice 2019-9 which provides interim guidance for the application of this new excise tax.  Please see our Special Report – IRS Notice 2019-9 Provides Interim Guidance for Tax-Exempt Organizations Paying Excess Executive Compensation – which provides a high-level summary of the Notice.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Melissa Ostrower Melissa Ostrower

Melissa Ostrower is a principal in the New York City, New York, office of Jackson Lewis P.C. and co-leader of the firm’s Employee Benefits practice group. She counsels clients in a broad range of employee benefit matters, including general compliance and administration of…

Melissa Ostrower is a principal in the New York City, New York, office of Jackson Lewis P.C. and co-leader of the firm’s Employee Benefits practice group. She counsels clients in a broad range of employee benefit matters, including general compliance and administration of qualified retirement plans and nonqualified retirement plans.

Melissa assists clients with welfare plan issues involving cafeteria plans, health plans, flexible spending accounts, COBRA and the Affordable Care Act. She regularly speaks on all benefits issues including federal health care reform, fiduciary compliance and executive compensation.

Melissa regularly advises on executive compensation matters, including issues related to compliance with Section 409A, 162(m) and 280G of the Internal Revenue Code.

Melissa represents clients in connection with Internal Revenue Service and the Department of Labor audits and information requests. She also regularly assists clients in fixing plan operational and document errors. Melissa negotiates with benefits providers, volume submitter and prototype vendors, TPAs, insurers and auditors.

Melissa also advises clients in connection with phantom and equity based compensation arrangements.

Photo of Suzanne G. Odom Suzanne G. Odom

Suzanne G. Odom is a principal in the Greenville, South Carolina, office of Jackson Lewis P.C. She focuses her practice on ERISA plans, employee benefits, and executive compensation matters.

Sue has worked extensively with all types of employer-sponsored retirement and welfare benefit plans…

Suzanne G. Odom is a principal in the Greenville, South Carolina, office of Jackson Lewis P.C. She focuses her practice on ERISA plans, employee benefits, and executive compensation matters.

Sue has worked extensively with all types of employer-sponsored retirement and welfare benefit plans, including pension, profit sharing, 401(k), 403(b), and 457(b) plans, ESOPs, and health, accident, disability, Section 125, flexible spending, and other welfare plans. Her clients include large and small for-profit companies across all industry sectors, non-profit corporations, and governmental entities.

As a result of Sue’s vast number of submissions and compliance matters, she has developed a close and professional working relationship with both the IRS and Department of Labor Representatives. Her practice is centered on providing her clients with solid and proactive fiduciary and business advice that assists them in avoiding the time and expense of employee benefits litigation.

Sue prides herself on her ability to think outside the box and work with clients to deliver the best business solutions possible.