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PeerBasis
Compensation Comparability Determination

We Are All Criminals

Executive Director / CEO

EIN 472085059
MN · NTEE R99
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Emily Baxter, Executive Director / CEO ($88,988) against every comparable organization that fit the selection criteria — 39 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 90th percentile of comparable organizationswithin the typical range

How comparable organizations were selected

39 organizations qualified on sector, size, and geography 39 within the band form the benchmarked peer set.

Distribution of comparable compensation

$80 total compensation of comparable organizations → $198,611 $88,988
$14,72010th
$22,49725th
$51,691Median
$71,51175th
$88,48690th
$88,988This org · 90th
p10$14,720
p25$22,497
p50$51,691
p75$71,511
p90$88,486
$88,988

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to MN cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateTotal revenueTotal compSource
Grassroots Global Justice ActionCA $90,460$80 990
Ka'ohana O KalaupapaHI $93,050$25,390 990
Institute For Research On Presidential ElectionsCA $94,829$73,407 990
Next Steps Florida IncFL $85,258$83,110 990
Right To Life Of So Indiana Educ FdIN $84,461$31,410 990
The Wclp Endowment FoundationCA $97,190$17,349 990
Action For A Progressive FutureCA $80,198$22,458 990
Ulysses S Grant Institute For The StudyAL $105,077$198,611 990
Center For Digital DemocracyDC $105,491$136,310 990
New York Civil Rights Coalition IncNY $106,226$86,877 990
Medgar And Myrlie Evers InstituteMS $106,645$72,329 990
Unitarian Universalists For Social JusticeDC $107,475$29,712 990
A Is ForNY $107,850$23,777 990
League Of Women Voters OfCA $108,868$61,590 990
Virginia Coalition For OpenVA $109,373$57,897 990
Illinois Alliance For Retired AmericansIL $109,743$56,107 990
Center For The Healing Of RacismTX $112,124$75,926 990
Sankofa ImpactWA $113,817$111,459 990
The Fund For Northern Tier DevelopmentPA $114,107$54,895 990
Rhode Island State Right To Life Committee IncRI $114,176$42,067 990
Maxcen-maxmath Women Society Inc Oklahoma BranchOK $65,539$5,618 990
Unity Women's Desk IncNC $115,519$65,845 990
Trunorth FoundationCO $115,536$70,693 990
Progress TexasTX $116,557$12,288 990
Black Socialists Of AmericaNY $63,862$64,015 990

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to MN cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default90th
Total compensation (D + F), as reported (no adjustments)85th
Reportable pay only (column D), adjusted90th
All sources (D + E + F), adjusted77th

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Emily Baxter) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 39 similarly situated organizations (Same NTEE major group (R), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $88,988 is reasonable (approximately the 90th percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.