WebMar 4, 2024 · IRC Section 4958 imposes an initial excise tax on both the disqualified person and any participating “organization manager” (i.e ., officer, director, trustee), based upon the portion of the compensation which is deemed “unreasonable.”. For a disqualified person, that tax equals 25% of the “unreasonable” portion. Web(a) Imposition of taxes (1) On the sponsoring organization There is hereby imposed on each taxable distribution a tax equal to 20 percent of the amount thereof. The tax imposed by this paragraph shall be paid by the sponsoring organization with respect to the donor advised fund. (2) On the fund management
eCFR :: 26 CFR 53.4958-3 -- Definition of disqualified person.
WebIRC 4966. Donors, donor advisors, and related persons are also subject to excise taxes if they receive more than an incidental benefit from a donor-advised fund. IRC 4967. The 4958 excess benefit transaction taxes were extended to include donors to DAFs and investment advisers to sponsoring organizations. IRC 4958(c), (f). WebOct 3, 2024 · See § 53.4958–4(b)(2)(i). (c) Requirements for invoking rebuttable presumption—(1) Approval by an authorized An authorized body means— (A) The governing body (i.e., the board of directors, board of trustees, or equivalent controlling body) of … city hall building inspector
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WebJan 9, 2004 · An Introduction to I.R.C. 4958 (Intermediate Sanctions) The 10% is payable by the organization managerwho participatedin the excess benefit transaction. The … Section 26 U.S. Code § 4958 - Taxes on excess benefit transactions U.S. Code Notes prev next (a) Initial taxes (1) On the disqualified person There is hereby imposed on each excess benefit transaction a tax equal to 25 percent of the excess benefit. See more There is hereby imposed on each excess benefit transaction a tax equal to 25 percent of the excess benefit. The tax imposed by this paragraph shall be paid by any disqualified … See more With respect to any 1 excess benefit transaction, the maximum amount of the tax imposed by subsection (a)(2) shall not exceed $20,000. See more To the extent provided in regulations prescribed by the Secretary, the term excess benefit transaction includes any transaction in which … See more If more than 1 person is liable for any tax imposed by subsection (a) or subsection (b), all such persons shall be jointly and severally liable for such tax. See more WebSection 4958 applies to all excess benefit transactions occurring on or after September 14, 1995. However, Section 4958 does not apply to excess benefit transactions that occurred under a written contract, if the contract was binding on September 13, 1995 and at all times thereafter before the excess benefit transaction occurred. city hall buffalo ny marriage license