Notice 2026-36 provides interim guidance that ATEOs can use when applying the Section 4960 excise tax after the OBBBA expanded the definition of a covered employee for taxable years beginning after Dec. 31, 2025.Until proposed regulations are issued, ATEOs can rely on the rules outlined in the notice, including the definition of covered employee for taxable years beginning after Dec. 31, 2025, while continuing to apply the prior definition for taxable years beginning before Jan. 1, 2026. Regulations implementing the OBBBA changes will not apply to taxable years beginning before the date that final regulations are issued.

Accede al recurso completo

Fuente: Crowe