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Equivalency Determinations Internal Revenue Service

Miller Nash LLP

An Athlete's Guide to Philanthropy, Nonprofit Organizations, and Community Impact: International Operations of U.S. Charities...

Miller Nash LLP on

The world is increasingly a global community, and this phenomenon is equally visible in sports as in the business and social arenas. With professional sports leagues spanning national borders in Major League Baseball, the...more

Butler Snow LLP

IRS Issues Guidance on US Private Foundation Equivalency Determinations for Grants to Foreign Public Charities

Butler Snow LLP on

On 14 September 2017, the IRS issued Revenue Procedure 2017-53, setting out the requirements for ‘preferred written advice’ upon which a US domestic private foundation can rely when making grants to non-US charities. This...more

Dechert LLP

Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more

Morgan Lewis

IRS Publishes Final Regulations for Equivalency Determinations

Morgan Lewis on

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

Farella Braun + Martel LLP

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

Goodwin

Private Foundations: A Brief Overview of Rules and Practical Steps for Grant-Making

Goodwin on

Private Foundation Rules to Remember - Private foundations must follow a variety of rules to avoid the imposition of potentially onerous penalty taxes on the foundation and its related parties...more

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