Nonprofits Finance & Banking International Trade

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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

Federal Budget 2015: What it Means for Employers

On 12 May 2015, Treasurer, Joe Hockey, delivered the Coalition Government's second budget. A key part of the budget is the Government's AUD5.5 billion 'Jobs and Small Business' package, aimed at assisting small businesses and...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

Why the Classic Legal Terminology of the Anglo-American Trust is in French, Not English: The “Law French” Phenomenon

The institution of the trust, a creature of the English Court of Equity, evolved deep in the bosom of the Anglo-American legal tradition. France, a civil jurisdiction, lacks a legal institution that is truly comparable. Her...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

United States Takes First Step in Liberalizing Sanctions on Burma

On April 17, 2012, the Department of the Treasury's Office of Foreign Assets Control (OFAC) released new General License 14-C, which authorizes financial transactions under specified circumstances in support of humanitarian,...more

Bribery Risks and Charitable Giving

The FCPA paparazzi has a standard list of anti-corruption risks: government interactions, third-party due diligence, gifts and entertainment, and mergers and acquisitions/joint ventures. Notice that charitable giving is not...more

United States Eases Sanctions on Financing for Development Organizations in Burma

On April 17, the U.S. Treasury issued new General License No. 14-C, which relaxes sanctions on financial services with respect to certain humanitarian and not-for-profit activities in Burma. This License allows...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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