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Internal Revenue Code (IRC) Tax Exempt Entities Tax Planning

Farella Braun + Martel LLP

Nonprofit Basics: IRS 10-Course Charity Workshop

In today's EO Radio Show episode, Cynthia Rowland reports on the IRS' recent promotion of a free 10-course workshop on basic topics for individuals interested in learning about tax-exempt organizations described in Internal...more

Katten Muchin Rosenman LLP

International Philanthropy: Considerations for the Globally Minded Donor

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction for...more

Rivkin Radler LLP

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

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Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more

Ballard Spahr LLP

Your Role in Protecting Tax-Exempt Bonds During Legislative Changes

Ballard Spahr LLP on

President Trump has indicated that one of his key economic priorities is to extend the expiring provisions of the Tax Cuts and Jobs Act (TCJA). However, Congress still needs to resolve disagreements on the cost and funding of...more

Wilson Sonsini Goodrich & Rosati

Eligibility of Life Sciences Companies for Qualified Small Business Stock

The “qualified small business stock” (QSBS) tax exemption under Section 1202 of the Internal Revenue Code allows non-corporate founders and investors in certain emerging growth companies organized as corporations to...more

Farella Braun + Martel LLP

Nonprofit Basics: Unrelated Business Income Tax: Basic Rules for Charities - Part 1

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and episode 107 is the first in a series of technical episodes describing the basic principles of the tax on unrelated business income generated...more

Freeman Law

IRC 509(a)(3) | Supporting Organizations Revisited

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Under the Internal Revenue Code (the “Code”), all organizations described in section 501(c)(3) are considered private foundations, unless one of four exceptions set forth in section 509 apply. Section 509(a)(3) is an...more

Partridge Snow & Hahn LLP

Key Considerations for Creating a For-Profit Subsidiary of a Public Charity

OpenAI, an artificial intelligence research nonprofit, has recently garnered media attention for considering a restructuring strategy involving the formation of a taxable subsidiary....more

Farella Braun + Martel LLP

Nonprofit Quick Tip: State Filings in North Carolina and South Carolina

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Episode 75 is the tenth in a series of Quick Tip episodes focusing on the details of state registration of nonprofit corporations. Today, Cynthia Rowland and Joe...more

Morgan Lewis

Inflation Reduction Act Guidance Anticipated on Direct Payment for Energy Credits

Morgan Lewis on

The Inflation Reduction Act of 2022 opened up many energy credit opportunities for tax-exempt organizations. Further guidance on the credit regime is anticipated in the coming months, which should help organizations determine...more

Freeman Law

Section 501(c)(3) Dissected: IRS Issues Detailed Guidance on Exempt Purposes

Freeman Law on

On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more

Freeman Law

Yeah, Science! IRS Issues Guidance Section 501(c)(3) Scientific Organizations

Freeman Law on

In the Netflix series, Breaking Bad, character Jesse Pinkman exclaimed, “Yeah, Science!!” as his meth-lab mentor, Walter White, displayed how chemistry can be used to hone their joint venture. While the activity in which they...more

Freeman Law

Adverse Rulings from the IRS Exempt Organizations Division. How Can Your Organization Learn from Others’ Mistakes?

Freeman Law on

On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more

Maynard Nexsen

Standards for Section 501(c)(3) Status of Limited Liability Companies

Maynard Nexsen on

The Internal Revenue Service (IRS) issued Notice 2021-56 - Standards for Section 501(c)(3) Status of Limited Liability Companies as its first attempt to set the standards for a limited liability company (LLC) to become a...more

Freeman Law

IRS Tax Exempt and Government Entities: A Summary of the Past Year

Freeman Law on

On January 6, 2022, the Tax Exempt and Government Entities (TE/GE) released its Fiscal Year 2021 Accomplishments Letter. Here is a summary below...more

Proskauer - Not for Profit/Exempt...

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

Miller Nash LLP

An Athlete's Guide to Philanthropy, Nonprofit Organizations, and Community Impact: Process and Pitfalls of Forming Nonprofit...

Miller Nash LLP on

As discussed in prior articles, there are several options for tax-incentivized giving, ranging from the informal and low-involvement to complex and highly involved structures. Many choose to adopt a more formal approach to...more

WilmerHale

What Nonprofits Should Learn From AG Lawsuits Against NRA

WilmerHale on

On Aug. 6, New York Attorney General Letitia James and D.C. Attorney General Karl Racine brought blockbuster lawsuits against the National Rifle Association and the National Rifle Association Foundation, alleging that these...more

Groom Law Group, Chartered

Proposed Section 4960 Excise Tax Rules for Tax-Exempts: Highlights and Key Features

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

Morgan Lewis

IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations

Morgan Lewis on

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 Shaw LLP

Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance

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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

Cozen O'Connor

IRS Issues Proposed Regulations for Tax on Nonprofit Executive Compensation

Cozen O'Connor on

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

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Emery on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

Saul Ewing LLP

Mayo Clinic Convinces Federal District Court (Minn.) That It Is an “Educational Organization” Entitled to Treat Its Debt-Financed...

Saul Ewing LLP on

The Mayo Clinic is granted a tax refund of $11.5 million, claiming that the income, even though unrelated to its exempt purposes and debt-financed, is nevertheless exempt from tax since the Mayo Clinic qualifies as an...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

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