The IRS has issued final regulations implementing the intermediate sanctions law. Section 4958 of the Internal Revenue Code authorizes penalties on tax-exempt organizations and its managers that authorize or engage in an "excess benefit transaction." The IRS published proposed regulations in 2005. The final regulations are important because they provide the factors the IRS will use in determining whether to revoke the tax-exempt status of an organization that participates in an excess benefit transaction. A key factor is whether the organization has a compliance program in place to detect and prevent an excess benefit transaction and whether it took appropriate corrective action.