Nonprofits International Trade Tax

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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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