WebIRC §4958(f)(1)(A); Treasury Regulations §53.4958-3(a). 10 IRC §4958. Council on Foundations 2121 Crystal Drive, Suite 700 Arlington, VA 22202 703-879-0600 www.cof.org 2 (not to exceed $20,000 with respect to any specific excess benefit transaction) is imposed on a foundation manager in his WebSection 4958 does not apply to payment of the $200,000 base salary (as adjusted for inflation), because it is a fixed payment pursuant to an initial contract within the meaning of paragraph (a) (3) of this section. By contrast, the annual bonuses that may be paid to S under the initial contract are not protected by the initial contract exception.

H. AN INTRODUCTION TO I.R.C. 4958 …

WebI.R.C. § 4958 (a) (1) On The Disqualified Person — There is hereby imposed on each excess benefit transaction a tax equal to 25 percent of the excess benefit. The tax imposed by … http://archives.cpajournal.com/2006/606/essentials/p36.htm opatch and mopatch

CFR Title 26. Internal Revenue 26 CFR § 53.4958-6 FindLaw

WebOct 9, 1999 · Section 4958 (f) (1) (A) uses the following definition: “any person who was, at any time during the 5-year period ending on the date of such transaction, in a position to exercise substantial influence over the affairs of the organization.” WebOn August 4, 1998, the IRS proposed regulations to implement IRC 4958. On March 16 and 17, 1999, the IRS held public hearings on these proposed regulations. It was not until January 10, 2001 that the IRS issued Temporary Regulations, which were … Web§ 53.4958-6 - Rebuttable presumption that a transaction is not an excess benefit transaction. (a) In general. Payments under a compensation arrangement are presumed … iowa farms butcher