Insider Transaction Traps for the Unwary
REFRESH Nonprofit Basics: Insider Transactions and Nonprofits
An Introduction to DAFs and Overview of the Newly Proposed DAF Regulations
2022 Significant Developments in the Tobacco Industry and What to Expect in 2023 (Part Two) - Regulatory Oversight Podcast
Change of Control: Golden Parachute Rules in the Sale Process
Lowndes Client Corner Podcast Episode 5 - Winter Park Distilling Company Brews One-Of-A-Kind Facility in Winter Park
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Episode 26: Talking Tax Reform and Executive Comp
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On May 12, 2025, the Republicans from the House Committee on Ways and Means released an updated draft tax bill. Several of the provisions in the draft would affect tax-exempt organizations. The bill will almost certainly...more
This week, the US House Ways and Means Committee released tax legislation that includes several provisions relevant to tax-exempt organizations....more
Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and this episode is a "refresh" of episode 32, recorded in March 2023. It covers the Internal Revenue Code sections pertinent to business...more
When considering compensation and benefits packages to lure and retain top executives or talent, nonprofit organizations, including universities and hospitals, are often at a disadvantage compared to their for-profit rivals....more
On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would...more
Donor advised funds (DAFs) are wildly popular with donors because they reduce the costs and administrative burdens of charitable grants and investing, thereby increasing amounts available for charitable giving. Since 2009,...more
Welcome to EO Radio Show - Your Nonprofit Legal Resource. I’m Cynthia Rowland, and episode 62 describes new proposed regulations important to the administration of donor advised funds. The Internal Revenue Service and the...more
This Freeman Law Insights blog provides an overview of the excess benefit transaction rules of 26 U.S.C. § 4958 and corresponding Treasury Regulations, 26 C.F.R. § 4958-1, et. seq....more
On March 1, 2022, the IRS published its 129-page Exempt Organizations Technical Guide TG 62 Excise Taxes on Taxable Expenditures. While not authoritative or controlling, the guidance addresses in great detail the definitions...more
The Week of July 26 – July 31, 2021 - Harrington v. Comm’r, T.C. Memo. 2021-95 | July 26, 2021 | Lauber, J. | Dkt. No. 13531-18 - Short Summary: Mr. Harrington is a U.S. citizen; his wife is a dual citizen of the...more
On January 19, 2021 the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published in the Federal Register Final Regulations (the “Final Regulations”) interpreting the excise tax under Section...more
For high-profile athletes commanding mega salaries and worldwide fame, giving back generously to their communities or to a cherished cause is a go-to play. Charitable giving carries limited risk while offering significant...more
Proposed Regulations under Section 4960 of the Internal Revenue Code provide important guidance for tax-exempt organizations and their affiliates regarding an excise tax on certain executive compensation. The U.S. Department...more
Proposed Regulations published by the Treasury Department last month provide helpful clarifications regarding the application of the excise tax under Section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”)....more
On June 12, 2020, the IRS released proposed regulations on the enforcement of Section 4960 of the 2017 Tax Cuts and Jobs Act. Section 4960 imposes a 21% excise tax on “applicable tax-exempt organizations” (ATEOs), including...more
Proposed Treasury regulations published earlier this month contain limited relief for tax-exempt entities. If followed carefully, those regulations can enable tax-exempt entities (and any related for-profit corporations) to...more
The Treasury Department (the “Department”) and Internal Revenue Service (“IRS”) recently released detailed proposed rules (the “Proposed Regulations”) interpreting Section 4960 of the Internal Revenue Code (the “Code”). 85...more
The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more
Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more
The US Department of the Treasury has released long-expected proposed regulations regarding the section 4960 excise tax on certain remuneration or separation amounts paid to the five highest paid employees of a tax-exempt...more
The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more
The tech explosion in West Coast cosmopolitan areas has exacerbated homelessness in the region, prompting state and local governments to enact or at least propose new taxes on large metropolitan businesses....more
On December 20, 2019, President Trump signed into law changes to the private foundation excise tax on net investment income under Section 4940 of the Internal Revenue Code. For purposes of Section 4940, net investment...more
Just in time for the holidays, Congress gave two gifts to tax-exempt organizations as part of the new government funding bill signed into law on December 20, 2019....more