News & Analysis as of

U.S. Treasury UBTI

ArentFox Schiff

Recent Priority Guidance Plan Shows Increased Focus on DAFs by IRS

ArentFox Schiff on

The US Department of the Treasury and the Internal Revenue Service issued its most recent Priority Guidance Plan Joint Statement (the Plan) on November 4, 2022. The Plan details more than 200 priorities for the 12-month...more

Troutman Pepper

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

Troutman Pepper on

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

Proskauer - Tax Talks

Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments

Proskauer - Tax Talks on

On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more

A&O Shearman

Proposed Regulations Clarify UBTI ‘Silo’ Rules, Preserve Relief For Tax-Exempt Investments in Private Equity Funds

A&O Shearman on

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) issued proposed regulations (REG-106864-18) addressing the so-called “silo” rule under Section 512(a)(6) of the Internal Revenue Code,...more

Bracewell LLP

IRS Relaxes UBTI "Siloing" Rules for Most Exempt Organizations

Bracewell LLP on

On April 23, 2020, the IRS and the Treasury Department released Proposed Regulations that provide guidance for how tax-exempt organizations (“EOs”) conducting multiple unrelated trades or businesses can calculate their...more

Carlton Fields

US Treasury and IRS Targets for Audit

Carlton Fields on

On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more

Williams Mullen

New Parking Expense Rules for Taxable Employers and Tax-Exempt Organizations

Williams Mullen on

The Internal Revenue Service issued guidance last December to help employers that own or lease employer parking facilities or reimburse employees for parking expenses to navigate the recent change to the parking expense...more

A&O Shearman

IRS Issues Guidance Affecting Tax-Exempt Investments in Private Equity Funds

A&O Shearman on

Under the Tax Cuts and Jobs Act (TCJA, December 22, 2017), tax-exempt investors must now calculate unrelated business taxable income (UBTI) separately with respect to each trade or business. As a result, a deduction from one...more

King & Spalding

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

King & Spalding on

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

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