International Trade Tax Nonprofits

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.
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IRS Publishes Final Regulations for Equivalency Determinations

Take note of these practical concerns for private foundations making grants to foreign organizations. On September 25, the Internal Revenue Service (IRS) published final regulations for private foundations making good...more

Final Regulations Provide Guidance for Private Foundations Making Foreign Grants

When making grants to foreign organizations, private foundations must conduct costly and time-consuming expenditure responsibility, unless the foundation makes a good faith determination that the foreign organization is...more

New Foreign Equivalency Determination Regulations

The IRS released final regulations under Internal Revenue Code Sections 4942 and 4945 on September 25, 2015, specifically addressing grants by private foundations to foreign organizations. These final regulations are partly...more

Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors [Video]

The Private Placement Group Variable Deferred Annuity Contract aka GAC has quietely been used by tax-exempt organizations for some time. As far as I can count, $50 billion of tax exempt transactions have utilized the GAC as a...more

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more

Second Circuit to address case of first impression by Plaintiffs against U.S. charities supporting violent fringe settler groups...

In a case of first impression, on April 15, 2015, the United States Court of Appeals for the Second Circuit will hear the case of Ahmad v Foundation for International Research and Education, DBA Christian Friends of Israeli...more

Religious Institution - January 2015

Experience over the last couple decades teaches that religious institutions face as much or perhaps more liability than secular organizations and, therefore, need to take risk management seriously. From operating their own...more

Foreign Charities and the Changing Landscape of CRA Charity Audits

There has been a flurry of recent scrutiny and activity in the areas of foreign and domestic charities – few foreign charities remain on the list of qualified donees since the changes to the definition of “qualified donee” in...more

Wealth Management Update - August 2014

August Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The August § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

International Grant-Making: Best Practices for U.S. Public Charities

U.S. public charities are blessed, but also challenged, by a relative lack of regulation governing their grants to foreign persons and foreign entities. U.S. public charities are blessed by this lack of regulation...more

Proposed Regulations Change Rules Governing Good Faith Determinations of a Foreign Organization’s Equivalence to a Public Charity

The IRS recently issued proposed regulations amending the rules applicable to a private foundation’s good faith determination that that a foreign grantee is the foreign equivalent of a public charity or private operating...more

IRS Issues Proposed Regulations To Make International Grant-Making By Private Foundations Easier

On September 24, 2012, the IRS issued Proposed Regulations §§ 53.4942(a)-3 and 53.4945-5 in order to reduce barriers to international grant-making made by private foundations. Secretary of State Hilary Clinton announced the...more

IRS Issues New Regulations to Facilitate Foreign Grantmaking

New rules expand the class of tax practitioners qualified to issue good-faith determinations regarding foreign-grantee equivalency; IRS seeks comments on further amendments to current regulations....more

IRS Tutorial Explains the Special Rules for International Activities of U.S. Charities

The IRS presents webinars on a variety of subjects. In August, the IRS presented a webinar conducted by two IRS representatives on the special rules affecting charities that make grants to foreign organizations or engage in...more

URGENT: Treasury Must Receive FBAR Filings by June 30 - for Most Filers

As reported in our prior blog entry, the Report of Foreign Bank and Financial Accounts, Form TD-F 90-22.1 (“FBAR”) must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a...more

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