Letter to Treasury on Excise Tax for Highly Compensated Employees

On August 10, MFA submitted a comment letter in response to Treasury’s proposed rules to implement the excise tax on highly compensated covered employees of tax-exempt organizations. The letter expresses support for the definitions of “employee” and “covered employee” in the proposed rules as they relate to non-compensated officers of tax-exempt organizations and employees of related organizations who provide limited services to a related tax-exempt organization or who provide services at no cost to the tax -exempt organization. These definitions reflect changes from the definitions in Treasury’s prior interim guidance that are consistent with MFA’s prior comments on the interim guidance.