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
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
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
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
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
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
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
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
The list is not intended to be exhaustive.
IRS rules that incentives to health care professionals and hospitals for using electronic records are income to those receiving the...more
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
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
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
The inflation adjustments for tax items for tax year 2014 of greatest interest to most taxpayers include the following dollar amounts....more
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
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
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
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
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
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
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
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
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
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
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
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
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