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UBTI Corporate Taxes

Goulston & Storrs PC

College & University Hotel Ownership Symposium – Key Takeaways

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We recently had the opportunity to co-sponsor and present during the College & University Hotel Ownership Symposium (CUHOS), on March 4-5 at Harvard University. The biennial event, organized by Pinnacle Advisory Group,...more

Seyfarth Shaw LLP

Net Operating Losses of Tax-Exempt Organizations with More Than One Unrelated Trade or Business

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Since the enactment of the unrelated business income tax in 1950, section 512(b)(6)[1] and its predecessor allowed organizations subject to the unrelated business income tax (UBIT) to use the net operating loss (NOL)...more

Bracewell LLP

Utilizing REITs for Midstream Assets

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The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more

BCLP

Form 990-T Fiscal Year 2017 Corporate Filers Apply Blended Rate to Unrelated Business Taxable Income (UBTI) for Entire Taxable...

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The IRS reminds Form 990-T Corporate Filers of new tax law provisions that could affect the tax rate applicable to their UBTI. Specifically, fiscal 2017 corporate filers should apply a blended rate to their UBTI for the...more

Snell & Wilmer

The Pass-Through Income Deduction for Charitable Remainder Trusts

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On January 18, 2019, the Internal Revenue Service (IRS) issued final regulations implementing the new pass-through income deduction for qualified business income (QBI) received from pass-through entities (such as sole...more

Poyner Spruill LLP

Recent IRS Guidance Details Cost of Providing Employee Parking

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Do you provide parking for your employees? If so, take note: the expense has gone up (and, for tax-exempt employers, may now result in additional tax liability!)....more

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Eversheds Sutherland (US) LLP

Highlighting itemized deduction limitations for private BDC investors

The Tax Cuts and Jobs Act (the Act), signed into law on December 22, 2017, amplifies the effects of certain deduction limitations as they apply to US-taxpaying individuals and other non-corporate investors in private business...more

Nutter McClennen & Fish LLP

Practical Insights on Tax Reform: Impact on Exempt Organizations

On December 22, 2017, President Trump signed into law legislation, known as the Tax Cuts and Jobs Act (“TCJA”), which is the most extensive overhaul of the United States Internal Revenue Code (the “Code”) in 30 years. In...more

Bracewell LLP

Private Funds Update - February 2018

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SEC's OCIE Announces 2018 Examination Priorities - ...On February 7, 2018, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released its 2018 examination...more

WilmerHale

Tax Act: New Laws Affecting Tax-Exempt Organizations

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The Tax Act contains a number of provisions that significantly affect tax-exempt organizations, in some cases to degrees not seen in decades. In addition, several provisions may indirectly affect tax-exempts, for example, by...more

King & Spalding

Impact of the New Tax Reform Legislation on the Real Estate Industry

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On December 22, the President signed the Tax Cuts and Jobs Act (“TCJA”) into law. TCJA changes the taxation of individuals and businesses in many ways. While there are still many open questions to be addressed by technical...more

Goulston & Storrs PC

Tax Reform Advisory:  Exempt Organizations

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On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to United States tax regimes for exempt organizations, businesses in which...more

Seyfarth Shaw LLP

Nonprofit Guide To The “Tax Cuts And Jobs Act”

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The 2017 “Tax Cuts and Jobs Act” impacts tax-exempt organizations in a variety of ways, including by reducing incentives for charitable giving, applying an excise tax on executive compensation in excess of $1 million per...more

Polsinelli

Tax Bill Causes Alarm for Some Charities and Tax-Exempt Organizations

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The Tax Cuts and Jobs Act, which has been renamed the Amendment of 1986 Code, was signed into law by President Trump on December 22, 2017. Many are calling it the most sweeping overhaul to the United States tax system in...more

Proskauer Rose LLP

U.S. Tax Reform – Key Highlights for Private Investment Funds in Tax Cuts and Jobs Act Bill

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On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill"). The Senate and the House are expected to vote on the Tax Bill this week. The Tax...more

Dechert LLP

Senate Passes Tax Reform Bill

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The U.S. Senate passed its version of the GOP tax reform bill, the Tax Cuts and Jobs Act (the “Senate Bill”), on Saturday, December 2, 2017. Shortly before approving the Senate Bill, the U.S. Senate adopted a Manager’s...more

Foley & Lardner LLP

How Proposed Tax Reform Will Impact Private Equity

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Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more

Proskauer - Tax Talks

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Dechert LLP

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

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The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

Akin Gump Strauss Hauer & Feld LLP

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more

Eversheds Sutherland (US) LLP

Proposed Regulation Incorporates IRS Litigation Position on UBTI for VEBAs and SUB Trusts

On February 6, 2014, the Internal Revenue Service (IRS) proposed new regulations for calculating the unrelated business taxable income (UBTI) of IRC section 501(c)(9) voluntary employees’ beneficiary associations (VEBA) and...more

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