Since 1995, Stephen Kirkland has provided analyses, reports and expert testimony on reasonable compensation for business owners, executives, professionals, trustees and directors. Their employers included professional service firms, closely-held businesses, hospitals and other tax-exempt organizations across the United States.
Reasonable Compensation Job Aid for IRS Valuation Professionals
The Reasonable Compensation issue usually involves a determination of whether the amount of compensation paid is reasonable so that it is deductible under section 162 of the Internal Revenue Code for income tax purposes. In some cases, the Reasonable Compensation issue comes up when the amount of compensation paid may be lower than reasonable to avoid the payment of employment taxes.1 For tax-exempt entities, the issue involves the application of section 4958, taxes on excess benefit transactions, and reflects a concern that excessively high compensation may unduly enrich officers, directors, trustees or key employees of the tax-exempt entity at the expense of the qualified charitable purpose....
REASONABLE COMPENSATION JOB AID APPENDICES
APPENDIX A: SUGGESTED READINGS ON REASONABLE COMPENSATION....
Challenges to "reasonable" compensation are among the most common, and most complex, issues raised in IRS audits of closely-held businesses and tax-exempt organizations. Similar issues arise in shareholder disputes and business valuations.
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