The IRS on July 23 issued final regulations (“Final Rules”) implementing the Internal Revenue Code section 506 requirement that an entity notify the IRS of its intent to operate as a Code section 501(c)(4) social welfare...more
The IRS’ new policy regarding employer identification numbers (“EINs”) could significantly delay the formation of new entities, especially by non-U.S. persons, unless practitioners and their clients get very proactive. ...more
Last December we told you about favorable IRS guidance letting P3 contractors and investors keep full tax deductions for interest on debt. The IRS kept a P3-friendly approach in last week’s proposed regulations on “qualified...more
5/7/2019
/ Capital Gains ,
Infrastructure ,
Interest Income ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Public Private Partnerships (P3s) ,
Qualified Opportunity Funds ,
Real Estate Development ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
Contractors and investors in P3s can continue taking a full tax deduction for interest on debt under recent IRS guidance (Revenue Procedure 2018-59, issued November 26). ...more
12/12/2018
/ Construction Project ,
Infrastructure ,
Interest Income ,
IRS ,
New Guidance ,
Project Finance ,
Public Private Partnerships (P3s) ,
Public Projects ,
Real Estate Development ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
Urban Planning & Development
At the same time that the IRS is making it easier for nonprofits to shield their donors from inadvertent disclosure, states continue to adopt new laws designed to shed light on who is funding politically active nonprofits. ...more
For several years, we have been describing the (increasingly successful) efforts by California state and local government agencies to increase their tax take through new and expanded fees and taxes on real estate...more
The recent tax reform bill (Tax Cuts and Jobs Act, H.R. 1), which the House Ways and Means Committee introduced November 2, would subject public pension plans to unrelated business income tax (“UBIT”) on their pre-packaged...more
11/10/2017
/ 501(c)(3) ,
Internal Revenue Code (IRC) ,
IRS ,
Legislative Agendas ,
Pensions ,
Proposed Legislation ,
Public Funds ,
Retirement Plan ,
Tax Code ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBIT
The California Supreme Court just dealt a blow to taxpayers who transfer interests in real estate-owning LLCs and other entities. In 926 North Ardmore Avenue, LLC v. County of Los Angeles (Cal. S. Ct. No. S222329, June 29,...more
The IRS has released a new, interactive Form 990-EZ (Short Form Return of Organization Exempt From Income Tax) to make the annual chore of return filing even easier for “small” tax-exempt organizations, and help them avoid...more
The California Franchise Tax Board (“FTB”) started 2017 with a setback as the Court of Appeal for the Fifth Appellate District held in Swart Enterprises, Inc. v. Franchise Tax Board that the FTB could not impose California’s...more
The Internal Revenue Service (IRS) recently released two position papers that affect new, and some existing, social welfare organizations described in section 501(c)(4) of the Internal Revenue Code (Code). Last month the IRS...more
Please join us for this complimentary presentation on cutting-edge employment law issues! California and federal employment laws are constantly developing and evolving so it is essential for human resource professionals and...more
Please join us for this complimentary presentation on cutting-edge employment law issues! California and federal employment laws are constantly developing and evolving so it is essential for human resource professionals and...more
Please join us for this complimentary presentation on cutting-edge employment law issues! California and federal employment laws are constantly developing and evolving so it is essential for human resource professionals and...more
Please join us for this complimentary presentation on cutting-edge employment law issues! California and federal employment laws are constantly developing and evolving so it is essential for human resource professionals and...more
If you have ever paid a current or ex-employee in a settlement or after a trial or arbitration (and what employer has not?), then you know the importance of properly characterizing the payment for tax purposes. For example,...more
The U.S. Supreme Court handed down its much-anticipated King v. Burwell decision on June 25, and (again) gave the Obama administration a huge victory by safeguarding its signature legislation, the Affordable Care Act...more
California state and local government agencies looking for more revenue have long been looking at real estate sales to increase their tax take. Last month, the California Court of Appeal for the Second Appellate District...more
A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more
For California's high-earners and business owners, Proposition 30's passage in November 2012 was a "cross the Rubicon" moment. First, Proposition 30 increased tax rates retroactively to the beginning of 2012....more
The U.S. Supreme Court in June struck down the Defense of Marriage Act (DOMA) provision preventing the federal government from recognizing a legally-valid marriage of a same-sex couple, and the Internal Revenue Service...more
We recently sent an E-Alert on what the recent Supreme Court same-sex marriage decisions mean for employers, but what do those decisions mean for the couples themselves in terms of employer and tax benefits?...more
8/9/2013
/ Civil Unions ,
DOMA ,
Domestic Partnership ,
Employee Benefits ,
Hollingsworth v Perry ,
Income Taxes ,
IRS ,
Marriage ,
Proposition 8 ,
Same-Sex Marriage ,
SCOTUS ,
US v Windsor
Starting in 2014, "large" employers (essentially, those with 50 or more "full-time" employees) must offer minimum health insurance coverage to full-time employees or face hefty penalties. These provisions (a.k.a "shared...more