Income Taxes, UBTI

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

Gerald Nowotny - Law Office of Gerald R.... on 8/7/2024

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

Gerald Nowotny - Law Office of Gerald R.... on 7/24/2024

I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

Troutman Pepper on 7/30/2020

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

New Treasury Regulations Address Income Aggregation Rules for Tax-Exempt Organizations

Kramer Levin Naftalis & Frankel LLP on 5/6/2020

On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) addressing the manner in which tax-exempt organizations calculate their...more

Nonprofits Seeking to Avoid New Parking Tax Must Make Changes Soon

McGuireWoods LLP on 3/14/2019

Thousands of nonprofits that provide parking benefits for their employees are subject to a new income tax on those benefits and have only weeks to avoid or minimize that tax liability for 2018. ...more

Addition of UBTI Siloing Rules Creates New Challenges for Tax-Exempt Organizations - Tax Update Volume 2019, Issue 2

Troutman Pepper on 3/11/2019

Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more

Recent IRS Guidance Details Cost of Providing Employee Parking

Poyner Spruill LLP on 3/5/2019

Do you provide parking for your employees? If so, take note: the expense has gone up (and, for tax-exempt employers, may now result in additional tax liability!)....more

New York City’s Unconscionable . . . Unexpected . . . Unincorporated Business Tax – A Glimpse Of...

Farrell Fritz, P.C. on 3/5/2019

Hell of a Town- Ask most New Yorkers what New York City has in abundance and you’ll get responses that are as varied as the personalities to whom the question is put. Museums, restaurants, performing arts, college...more

Tax Law Changes Complicate Tax-Exempt Organizations’ Attempts to Calculate UBTI

McGuireWoods LLP on 12/14/2018

Charities and other exempt organizations face higher taxes, more complex returns and tough investment decisions under new unrelated business income tax rules effective for 2018. Despite recent guidance from the Internal...more

IRS Issues Guidance on Calculating UBTI Under New Section 512(a)(6)

Morgan Lewis on 9/6/2018

With some exceptions, organizations subject to the unrelated business income tax under Section 511 that have more than one unrelated trade or business may rely on a “reasonable, good-faith interpretation of §§ 511 through...more

Tax-Exempts May Limit Fund Investments Pursuant to New IRS Guidance on UBTI

Proskauer - Not for Profit/Exempt... on 9/5/2018

On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-67 (the “Notice”), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6) of the Internal Revenue Code (the...more

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

Bradley Arant Boult Cummings LLP on 8/13/2018

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Let’s BOND over the Tax Act Part II - The Higher Education Edition

Bond Schoeneck & King PLLC on 1/29/2018

In the spirit of accentuating the positive, there are a few bits of good news for colleges and universities in the Tax Act…as Mary Poppins might say, a spoonful (or three) of sugar to help the medicine go down. Unfortunately,...more

Tax Reform Advisory: Exempt Organizations

Goulston & Storrs PC on 12/28/2017

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to United States tax regimes for exempt organizations, businesses in which...more

Nonprofit Guide To The “Tax Cuts And Jobs Act”

Seyfarth Shaw LLP on 12/26/2017

The 2017 “Tax Cuts and Jobs Act” impacts tax-exempt organizations in a variety of ways, including by reducing incentives for charitable giving, applying an excise tax on executive compensation in excess of $1 million per...more

Tax Bill Causes Alarm for Some Charities and Tax-Exempt Organizations

Polsinelli on 12/22/2017

The Tax Cuts and Jobs Act, which has been renamed the Amendment of 1986 Code, was signed into law by President Trump on December 22, 2017. Many are calling it the most sweeping overhaul to the United States tax system in...more

Senate Passes Tax Reform Bill

Patterson Belknap Webb & Tyler LLP on 12/15/2017

On November 16, the House of Representatives passed an amended version of H.R. 1, the “Tax Cuts and Jobs Act,” by a vote of 227-205 (the “House Bill”). On November 20, 2017, the Senate Finance Committee released the Senate’s...more

How Proposed Tax Reform Will Impact Private Equity

Foley & Lardner LLP on 11/27/2017

Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

Dechert LLP on 11/10/2017

The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Effects of House Tax Reform Bill on Securitizations and Funds

Cadwalader, Wickersham & Taft LLP on 11/9/2017

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

Akin Gump Strauss Hauer & Feld LLP on 11/8/2017

• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more

New Rules for Tax-Exempt Organizations in the Tax Cuts and Jobs Act

Proskauer - Not for Profit/Exempt... on 11/7/2017

House Republican Tax Bill Imposes Excise Tax on Wealthy Private Universities and Excess Compensation of Highly Paid Employees; Subjects State Pension Plans to UBTI Rules - On Thursday, November 2, House Republicans led by...more

Tax Reform Bill Proposes to Eliminate UBTI Exemption for Government Plans

Morgan Lewis on 11/6/2017

House bill, if enacted, will alter tax analysis with respect to fund investments. On November 2, House Republicans released their draft tax reform bill. Of particular interest to government pension plans is a provision...more

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Holland & Knight LLP on 12/1/2016

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

Income Taxes › UBTI

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