As private foundations and other charitable organizations look forward to the end of the coronavirus pandemic and the return of in-person events, it may be a good idea to review the self-dealing rules involving event tickets...more
Tax-exempt organizations (including private foundations, which are subject to special additional disclosures) are subject to certain public disclosure rules. These rules require that the organization make its exemption...more
Part 1 of our Article addressed why a charitably-inclined client should make a gift to charity in the year of business sale.
Having completed the analysis of when it is best to make a gift, some clients may hesitate to...more
1/27/2021
/ Adjusted Gross Income ,
Charitable Donations ,
Charitable Lead Annuity Trust ,
Charitable Organizations ,
Charitable Remainder Trust ,
Estate Tax ,
Gift Tax ,
Income Taxes ,
IRS ,
Split-Interest Charitable Trusts ,
Tax Deductions
We are nearing the end of calendar year 2020 (thankfully!) and it is time to consider end-of-year tax planning. Due to the outcome of the election, there is significantly more certainty about the possibility of tax law...more
Many grantmakers are unaware, but private foundations can make direct grants to individuals to further the private foundation’s exempt purpose. Private foundations often focus their grantmaking programs on making grants to...more
On Tuesday, November 3rd, Americans went to the polls and cast votes for President, Senators, and House members. In some cases, the results are still being tabulated (or subject to challenge). However, the picture becomes a...more
Formation -
Requires formation of a new corporation or trust; must apply for IRS exempt status.
Simple application and donor advised fund agreement with sponsoring organization. ...more
As explored in a previous article, the IRS clarified that mission-related investments (MRIs) will not trigger the private foundation “jeopardy investment” rule (that is, a private foundation cannot make investments that would...more
The November 3 election may have dramatic impacts on the income and estate tax laws. These changes could become effective as early as January 1, 2021. Of course, a big uncertainty is the outcome of the election, and whether...more
Private foundations are subject to special rules relating to conflicts of interest. These are called “self-dealing” rules. These rules flatly prohibit transactions between interested persons (known as “disqualified persons”)...more
At the end of June, the Commissioner of the IRS Large Business and International Division announced a new campaign to audit high-net-worth individuals and the entities (such as partnerships, corporations, trusts, and private...more
New proposed IRS regulations clarify that the tax will not apply in most cases when company officers/employees serve as directors and officers of the company foundation for no compensation from the foundation
In a prior blog...more
Foundations, like many investors, are considering how to use their assets to both provide investment return and to promote their social and charitable causes (a strategy sometimes referred to as “social impact investing”). ...more
Under the CARES Act (Coronavirus Aid, Relief, and Economic Security Act), the federal government will pay 50% of the reimbursable unemployment benefits from March 13, 2020 through December 31, 2020 for those non-profit...more
4/16/2020
/ Banks ,
Business Closures ,
Business Interruption ,
CARES Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Loans ,
Financial Stimulus ,
Health Care Providers ,
Healthcare ,
IRS ,
Lenders ,
Lending ,
Nonprofits ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
State and Local Government ,
Tax Relief ,
Unemployment Insurance
As the COVID-19 pandemic continues, businesses may consider having their affiliated company foundations take the lead on providing assistance to affected employees and their families. This is permitted, but companies must...more
In a January 31, 2020 private letter ruling (PLR 202005020), the IRS ruled that where a Parent 501(c)(3) non-profit organization was providing administrative services to a for-profit Subsidiary, the Subsidiary’s creation and...more
In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more
7/15/2016
/ 501(c)(3) ,
ACOs ,
Affordable Care Act ,
Exempt Organizations ,
Health Care Providers ,
Hospitals ,
IRS ,
Medicare Shared Savings Program ,
Physicians ,
Private Letter Rulings ,
Third-Party ,
Unrelated Business Income Tax