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Tax Exemptions Internal Revenue Service

Planning for 2018

by Dickinson Wright on

Even if Congress fails this autumn to overhaul the Internal Revenue Code and, conceivably, repeal the federal “death” or estate tax, 2018 can be expected to bring relief in the form of taxpayer-friendly inflation adjustments....more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

Projected Estate and Gift Tax Exemptions for 2018 – How Much Can You Transfer?

by McNair Law Firm, P.A. on

The Consumer Price Index was released by the Labor Department in August 2017. Not everyone anxiously awaits the release of these numbers but the experts have now made estimates of how they will impact estate, gift, and...more

Estate Tax Portability – Not So Fast My Friend

by Dickinson Wright on

Many of you have heard of the new Federal estate tax “portability” rule that allows a surviving spouse to effectively inherit any unused federal estate tax exemption of a predeceased spouse. An individual can only use the...more

Wealth Management Update - September 2017

by Proskauer Rose LLP on

September Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The September § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Practical Issues Facing Nonprofits Structuring New Market Tax Credit Deals

by Blank Rome LLP on

Since the Great Recession, nonprofits have been receiving less support from budget-constrained governmental agencies and fewer contributions from the private sector. Similarly, many state and other nonprofit universities have...more

Can Financial Institutions Use In-House Funds for Their Own Retirement Plans?

by Burns & Levinson LLP on

Financial institutions that sell mutual funds to the public often maintain 401(k) and other retirement plans for their own employees. In these plans, many financial institutions make their own mutual funds available to...more

IRS Focuses on Tax Exempt Financings Involving Developers

For a number of years, the IRS Office of Tax-Exempt Bonds ("TEB") has expressed concerns about potential tax abuses that may exist in what it has characterized as "developer-driven deals" involving the use of tax-exempt...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

IRS issues Rev. Proc. 2017-34 to Extend Time to Make Portability Election

by Dickinson Wright on

For individuals dying after December 31, 2010, Section 2010(c) of the Internal Revenue Code provides that the unused estate tax exemption of the first deceased spouse is “portable” between spouses at death. Under this law, a...more

PACs, Campaigns and Dark Money: What is the Law?

by Stinson Leonard Street on

In 2016, Missouri voters enshrined new campaign finance laws in the state constitution. The Missouri Ethics Commission issued several interpreting opinions and a federal court has enjoined parts of the law as...more

Is It the End of the Johnson Amendment as We Know It?

While speaking at the National Prayer Breakfast on February 2, 2017, President Trump reaffirmed his commitment to repeal the law that restricts organizations that are tax exempt under Section 501(c)(3) of the Internal Revenue...more

Personal Planning Strategies - December 2016

by Proskauer Rose LLP on

2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

2016 Year-End Estate Planning Advisory

by Katten Muchin Rosenman LLP on

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Higher Education, Exempt Organization & Governmental Financings - Tax Presentation

Qualified Equity - Allocation & Accounting Rules for Private Business Use - New Treasury Regulations regarding measurement and allocation of private business use (PBU) benefit universities that finance a...more

The 5% Solution: IRS Revenue Procedure 2016-42 Provides Relief for the Probability of Exhaustion Test

by M. Robinson & Company, P.C. on

Charitable Remainder Annuity Trusts (CRATs) can be a very effective charitable planning tool. Choosing to fund a CRAT can remove assets from the estate of the donor, provide a reliable income stream for a family member and...more

Updated Historical Transfer Tax Rates & Exemptions

by Charles (Chuck) Rubin on

Please see chart below for more information....more

Employee Benefits Developments - September 2016

by Hodgson Russ LLP on

Final IRS Regulations Eliminate Requirement to File 83(b) Election with Tax Return - Under Section 83(a) of the Internal Revenue Code (the “Code”), if property is transferred in connection with the performance of...more

IRS Continues Trend of Flexibility for Qualified Management Agreements (QMA’s) for Hotels Financed With Tax Exempt Bonds

by Kelley Drye & Warren LLP on

The US Internal Revenue Service (IRS) recently continued a trend of pronouncements further extending flexibility in structuring a Qualified Management Agreement (QMA) for a hotel financed with tax exempt bonds without...more

Put Me in Coach! Using Split Dollar Life Insurance Plans to Compensate Division I Coaches

by Gerald Nowotny on

In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more

The next chapter - A new bond linking financial returns to environmental or social goals could thrive. But securities law...

by Morrison & Foerster LLP on

Shakespeare’s Juliet may not have ascribed great significance to a name but for securities lawyers and market participants alike there is significance to nomenclature. Social impact bonds, or investments that are intended to...more

No Recess - The Importance of Post-Issuance Compliance Policies and Procedures for New York State School Districts

Tax-exempt bonds and notes, the interest on which is exempt from federal income taxation, are routinely issued by school districts across New York State to finance a wide variety of capital projects and to refinance existing...more

IRS Issues New Management Agreement Safe Harbor Provisions, Providing Enhanced Flexibility for College and University Food...

New management agreement guidelines were issued by the IRS today in a new Revenue Procedure (Rev. Proc.) 2016-44. Rev_Proc_2016-44 provides revised safe harbors under which a private management contract does not result in...more

D.C. Circuit Court Gives Victory to Conservative Non-Profit Groups Targeted by IRS

by Clark Hill PLC on

Last week, the U.S. Court of Appeals for the D.C. Circuit reversed two district court decisions that had dismissed the claims of dozens of conservative non-profit organizations (the "Plaintiffs") in the Internal Revenue...more

IRS Announces Major Qualified Plan Determination Letter Program Change

by GableGotwals on

The Internal Revenue Service has published very important new guidance on assuring employer sponsored pension and profit sharing plans qualify for tax exemption. Revenue Procedure 201637, 2016-29 Internal Revenue Bulletin,...more

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