News & Analysis as of

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

IRS Report Scrutinizes Unrelated Business Income Reporting by Tax-Exempt Organizations

The Internal Revenue Service (IRS) has released a final report (the “Report”) summarizing its findings from a study focused on the level of compliance by tax-exempt colleges and universities with respect to unrelated...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

Tax-Exempt Financing for Tax-Exempt Organizations: Is Your Nonprofit Eligible, and Do the Benefits Outweigh the Costs?

In this presentation: - Eligible Organizations: Those qualified under Section 501(c)(3) of the Internal Revenue Code. - More complicated than the typical bank loan. - To qualify for tax exemption, the...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

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

IRS Issues Proposed Regulations for Section 501(c)(3) Tax-Exempt Hospitals Regarding the Community Health Needs Assessment...

On April 5, 2013, the Internal Revenue Service ("IRS") published proposed regulations ("Proposed Regulations") providing guidance regarding certain aspects of Section 501(r) of the Internal Revenue Code ("Code"), which...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

Portability

Congress recently made permanent the “portability” of a predeceasing spouse’s unused estate tax exemption (currently, $5.25 million per spouse)....more

Estate, Gift, and GST Taxes in 2013: American Taxpayer Relief Act of 2012 and Other News (Oregon)

The American Taxpayer Relief Act of 2012 (the “Act”) was signed into law on Jan. 2, 2013, avoiding dramatic changes to tax exemptions and tax rates on transfers subject to federal estate, gift, and generation-skipping...more

What the “Fiscal Cliff” Resolution Means for Personal Estate Planning

For the first time in 12 years, the estate, gift and generation-skipping transfer tax law does not have a built-in expiration date in the United States. Congress has exempted all estates below approximately $5 million ($10...more

FINALLY…Clarity And Good News On Estate And Gift Taxes

It has often been said that the only things in life that are certain are death and taxes. Until two weeks ago, the “taxes” part of that phrase was not so certain. However, on January 2, 2013 President Obama signed the...more

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