The IRS released Parts I and II of its Report on Exempt Organizations Executive Compensation Compliance Project earlier this month. Part I involved compliance check letters sent to 1,223 organizations. Part II involved examinations of 782 organizations. Among the findings of the Report:
- Significant reporting issues exist. Over 30% of compliance check recipients amended their Forms 990.
- Examinations completed to date (about 10% remain open) do not evidence widespread concern other than reporting.
- Where problems were found, significant dollars are being assessed (25 examinations have resulted in proposed excise tax assessments aggregating in excess of $21 million against 40 disqualified persons or organization managers).
- Additional education and guidance are needed in the areas of reporting requirements and the "rebuttable presumption" procedure that may be relied upon by public charities to establish appropriate compensation.
- Changes in the Form 990 series are necessary to reduce errors in reporting and provide sufficient information to enable the IRS to identify compensation issues.
You can read Parts I and II of the Report here.