IRS Notice 2026-36: How OBBBA's Expanded 21% Excise Tax on Nonprofit Executive Pay Now Reaches Every Employee, Not Just the Top Five
OBBBA expanded Section 4960 from the top five to every current and former employee after 2016. Learn how Notice 2026-36 previews proposed rules, who counts as an ATEO, and what nonprofits must track for the 21% tax on pay over $1 million in 2026.
small-business
nonprofit
tax-compliance
