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IRS Issues Proposed Regulations on Donor-Advised Funds

Since the enactment of the statutory donor-advised fund (“DAF”) rules under the Pension Protection Act of 2006, sponsoring organizations that manage DAF programs have relied on the Internal Revenue Code (“IRC” or the “Code”)...more

Protective Refund Claims in Light of Pending Moore v. United States Decision

Taxpayers, including some of the firm’s current and former clients, may be affected by the outcome of the Supreme Court case Moore v. United States, which will address the constitutionality of the Section 965 “Transition...more

Proposed 4960 Excise Tax Regulations Issued

On June 5, 2020, the Internal Revenue Service (“IRS”) issued proposed regulations on the excise tax on excess tax-exempt organization executive compensation under Section 4960 of the Internal Revenue Code (the “Excise Tax”)....more

6/17/2020  /  Excise Tax , IRS

New Rules on Section 83(b) Elections

Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more

Proposed Disregarded Entity Regulations: Potential Implications for Charities

On May 10, 2016, the Internal Revenue Service (“IRS”) published proposed regulations that would impose additional reporting and record-keeping requirements on domestic “disregarded entities” that are wholly owned (directly or...more

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

Provisions Affecting Charities in Proposed Budget

The Administration’s proposed budget for Fiscal Year 2017 features several proposals that would impact charitable organizations and their donors, including proposals to streamline the private foundation excise tax on net...more

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