Illustration of the expanded IRC section 4960 21% excise tax on nonprofit executive compensation over $1 million under OBBBA and IRS Notice 2026-36
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Nonprofit §4960 Excise Tax Expands Under OBBBA (Notice 2026-36)

How did OBBBA expand the §4960 excise tax on nonprofit executive compensation? Internal Revenue Code §4960 imposes a 21% excise tax on a tax-exempt organization’s “excess remuneration” — compensation over $1 million paid to a covered employee — plus certain excess parachute (separation) payments. Under the One, Big, Beautiful Bill Act, beginning with tax years…