Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut
EV Tech Series: The Inflation Reduction Act’s Impact on the Energy Industry With Judy Kwok and Marc Machlin - Battery + Storage Podcast
Tribal Tax Exemption Under McGirt Gains Preliminary Victory
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
ATTENTION ALL CADETS!
One Note Samba
Podcast: State Taxation of Digital Health Products
Investment Management Roundtable Discussion – Personal Estate Planning
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Episode 26: Talking Tax Reform and Executive Comp
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
New York Estate Tax Law Changes
On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more
As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more
Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more
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
June 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more
As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more
Beginning January 1, 2024, many types of legal entities must report information regarding their “beneficial owners” and certain other information (collectively, “BOI”) to the Financial Crimes Enforcement Network (“FinCEN”)....more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
For many weeks, we’ve been hearing about the IRS’s plans to use the funding provided under the Inflation Reduction Act[i] to increase and expand its compliance and enforcement efforts with respect to the wealthy, high-income...more
If you own your principal residence, you may be able to benefit from its build-up in equity, realize current tax breaks and pocket a sizeable tax-exempt gain when you sell it. What’s more, from an estate planning perspective,...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023. July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30,...more
Summary - The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 – May 12, 2023...more
Summary: Commonwealth challenges the IRS’s denial of application for tax exemption under 501(a), claiming, by submission for declaratory judgment, to be an organization described in section 501(c)(15). Commonwealth was...more
Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more
On September 16, 2022, the IRS published its Exempt Organizations Technical Guide TG 6 IRC 501(c)(6) Business League (“TG6”). TG6 discusses tax exemption of business leagues, chambers of commerce, real estate boards, and...more
Can and should your religious organization seek church status with the IRS? A look at a few pros, cons, and due diligence considerations....more
On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more
This Insights blog is Part 3 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more
Transfers of real property to certain qualifying entities will no longer be subject to real estate excise tax in Washington State, effective on January 1, 2023. The Washington State Legislature passed Engrossed House Bill...more