News & Analysis as of

California (Finally) Conforms to Federal Treatment of UBTI in Charitable Remainder Trusts

One of the most important tax attributes of charitable remainder trusts is that they are exempt from income tax – except, that is, when it comes to unrelated business taxable income (UBTI) of these trusts. For decades the...more

IRS and Department of Treasury Release 2014-2015 Priority Guidance Plan

On August 26, 2014, the IRS and the Department of the Treasury issued the 2014-2015 Priority Guidance Plan. The Priority Guidance Plan includes 18 exempt organization law projects and four projects relating to charitable...more

The Eye of the Beholder

“A tax loophole is something that benefits the other guy. If it benefits you, it is tax reform.” – former U.S. Senator Russell B. Long (D – Louisiana). “The precise point at which a tax deduction becomes a ‘loophole’...more

Hospital's Lab Testing for Non-Patients Held to be Related Activity

On July 11, 2014, the IRS released a Technical Advice Memorandum ("TAM") finding that a tax-exempt hospital's income from the performance of laboratory services for non-patients was not subject to the unrelated business...more

IRS Applies 20th Century Analysis To 21st Century Social Organization

Code §501(c)(7) provides an exemption from federal income tax for clubs organized substantially for pleasure, recreation, and other nonprofitable purposes if no part its net earnings inures to the benefit of a private...more

Time Limitations On Receiving Late Proof Of Foreign Status For Portfolio Interest Exemption Payments

Code Section 871(h) provides non-U.S. persons with a valuable exemption from U.S. income taxes on interest paid on registered U.S. obligations, commonly referred to as the portfolio interest exemption. Before a payor is...more

Thinking of Moving to Florida? Maybe a Little Further South is a Better Option

In an effort to revitalize its economy, Puerto Rico has passed tax laws intending to attract investment to the island. Located two hours from Florida, the Caribbean territory of the U.S. offers several substantial tax...more

"Nonprofit Traps and Pitfalls"

Many of us lawyers are involved with nonprofits. Some of us assist clients in incorporating and providing legal advice to nonprofits, and others of us serve on nonprofit boards. Nonprofit law is surprisingly complex. ...more

Significant Changes to New York Estate and Income Tax Enacted

We previously alerted you to proposed legislation affecting New York estate tax law, the tax treatment of gifts by New York residents, and New York income taxation of certain trusts. This month Governor Cuomo signed final...more

Significant Changes Proposed to New York Estate and Income Tax Laws

The New York State Legislature is considering some significant proposed changes to the New York estate tax law, the tax treatment of gifts by New York residents, and New York income taxation of certain trusts. Some important...more

Updated Procedures For Reinstating Tax-Exempt Status: IRS Issues Revenue Procedure 2014-11

In This Issue: - What You Need to Know - Methods to Reinstate Tax-Exempt Status Smaller Organizations Applying Within 15 Months of Revocation Date - Organizations Not Eligible for the Streamlined Process Applying...more

Important 2014 Tax Developments

The list is not intended to be exhaustive. - Income: IRS rules that incentives to health care professionals and hospitals for using electronic records are income to those receiving the...more

Top 10 Indian Tribal Tax Developments in 2013 and Priorities for 2014

In 2013, courts were active in issues relating to Indian tribes, including ruling on state tax matters and the federal income tax aspects of Section 17 corporations. The top 10 Indian tribal tax developments from 2013...more

U.S. Tax Court Decision Shows Importance of Carefully Drafting Settlement Agreements

In Sharp v. Commissioner, the United States Tax Court once again demonstrated the importance of carefully crafting settlement agreements and reaffirmed that emotional distress damages are taxable income to the recipient....more

100 Percent Tax Exemption for Gain on Certain Qualified Small Business Stock Expiring at Year End

In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more

2014 Annual Inflation Adjustments for Tax Provisions

The inflation adjustments for tax items for tax year 2014 of greatest interest to most taxpayers include the following dollar amounts....more

Income Tax Cost Basis Planning

Prior to the recent and significant increases in the federal estate tax exemption amount, many clients engaged in planning the purpose of which was to ensure the use of both spouses’ exemption amount through the use of a...more

Public Concerns Lead IRS to Offer Expedited Process for New Social Welfare Organizations

A wide array of organizations can qualify to be recognized as exempt from federal income taxes. Most noted of late are those organizations which are structured to “promote social welfare” and which can seek tax-exempt status...more

Recent Developments Affecting Global Stock Plans

As noted in Pillsbury’s May 12, 2011 Advisory, Going Global with US Employee Stock Plans, sponsors of global stock plans must navigate a host of legal and tax regimes to maintain compliance with applicable rules and laws....more

Tax Free Income For Up To 14 Days Rental Of Personal Residence

Planning a vacation this summer but don't know how to finance it? Consider renting out your personal residence while you are away and pocketing the rental income tax-free!...more

Supreme Court DOMA Decision—Part I: Fringe Benefits and Other Tax Implications

On June 26, 2013, the Supreme Court of the United States issued its highly anticipated decision in United States v. Windsor, ruling that Section 3 of the federal Defense of Marriage Act (DOMA) is unconstitutional....more

Supreme Court Finds DOMA to Be Unconstitutional -- Impact on Employers Explained

On June 26, 2013, a majority of the Supreme Court held in United States v. Windsor that Section 3 of the Defense of Marriage Act (DOMA), which defined marriage for purposes of federal law as the union of a man and a woman, is...more

A long engagement: Married same-sex couples finally receive post-DOMA access to federal tax and estate planning benefits

The U.S. Supreme Court’s ruling in United States v. Windsor will forever change many facets of the lives of same-sex couples....more

Italy: Government Extends Scope of Application of “Robin Hood Tax”

On 21 June 2013, Law Decree no. 69 of 21 June 2013 (the Decree) was published in the Official Gazette. Among many other provisions aimed at supporting the Italian economy, the Decree significantly extends the scope of...more

Wrap-Up of Alabama Legislature Actions

The Alabama Legislature adjourned near midnight on May 20, closing a session that saw lawmakers grant final passage of the two operating budgets and of amendments to the controversial Alabama Accountability Act. With respect...more

40 Results
|
View per page
Page: of 2