Section 4960 of the Internal Revenue Code imposes an excise tax on certain executive compensation paid by applicable tax-exempt organizations. While the basic framework of Section 4960 has remained in place since 2017, Congress amended the statute in 2025 to expand the definition of a covered employee and provide for annual inflation adjustments to the remuneration threshold. The IRS has also issued Notice 2026-36 providing initial guidance on how it intends to interpret the
