The world is increasingly a global community, and this phenomenon is equally visible in sports as in the business and social arenas. With professional sports leagues spanning national borders in Major League Baseball, the...more
On 14 September 2017, the IRS issued Revenue Procedure 2017-53, setting out the requirements for ‘preferred written advice’ upon which a US domestic private foundation can rely when making grants to non-US charities. This...more
The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more
Take note of these practical concerns for private foundations making grants to foreign organizations. On September 25, the Internal Revenue Service (IRS) published final regulations for private foundations making good...more
When making grants to foreign organizations, private foundations must conduct costly and time-consuming expenditure responsibility, unless the foundation makes a good faith determination that the foreign organization is...more
Private Foundation Rules to Remember - Private foundations must follow a variety of rules to avoid the imposition of potentially onerous penalty taxes on the foundation and its related parties...more