News & Analysis as of

Internal Revenue Code (IRC) Tax Exemptions

Davis Wright Tremaine LLP

House GOP Tax Proposal Targets Nonprofits

On May 12, 2025, the House Ways and Means Committee released a draft version of the Republican-led tax bill, "The One, Big, Beautiful Bill" (the "Bill"), which is designed to advance President Trump's tax reform agenda. The...more

Partridge Snow & Hahn LLP

Tax-Exempt Financing for 501(c)(3) Borrowers – Part I: Eligibility and Issuance

When borrowing for capital projects, 501(c)(3) borrowers often have various options to achieve their financing goals. Traditional financing through a bank or engaging in specific capital campaign fundraising efforts are...more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

King & Spalding

Ways and Means Committee Seeks Information Regarding OPO Activities

King & Spalding on

On April 16, 2025, the Committee on Ways and Means in the U.S. House of Representatives issued a letter to the public requesting information regarding Organ Procurement Organizations (OPOs)—the nonprofit, tax-exempt entities...more

Winstead PC

The QPAM Exemption - Key Takeaways for Fund Managers with Benefit Plan Investors

Winstead PC on

As an asset manager, you may be familiar with the regulatory issues that come into play when a fund permits investments from “benefit plan investors,” which generally include certain employee benefit plans subject to the...more

Allen Matkins

The Possible Securities Act Implications Of Harvard's "Nyet" To Government Civil Rights Reform Demands

Allen Matkins on

Last week, the United States General Services Administration, Department of Education, and Department of Health and Human Services sent a letter to Alan M. Garber, the President of Harvard University, and Penny Pritzker, Lead...more

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

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Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Proskauer - Employee Benefits & Executive...

A Trap for the Unwary – Nonprofit Organization Compensation Arrangement Considerations for High Caliber Executives

Like any for-profit company, nonprofit organizations want to attract and retain high caliber executives to achieve and further their missions. To accomplish this, a nonprofit organization may have to offer a particularly...more

Chambliss, Bahner & Stophel, P.C.

Tax Break Helps Pay for CCRC Fees

A lesser-known financial upside of Continuing Care Retirement Community (CCRCs) is the potential tax deductibility of a portion of the entrance fee and monthly fees....more

Best Best & Krieger LLP

403(B) Plan Employer Eligibility Failures

One of the principal drivers of 403(b) Plans for governmental agencies is that when they are combined with a governmental 457(b) Plan, employees eligible for both plans may “double dip.” This is a common scenario for...more

Husch Blackwell LLP

IRS Cutbacks May Impact Healthcare M&A Transactions

Husch Blackwell LLP on

Kevin’s practice involves guiding clients through the complexities of federal, state, local and international taxation. Kevin routinely advises business entities, tax-exempt organizations and high net worth individuals on a...more

Freeman Law

Texas Tax Update | Federal Preemption of Taxable Security Services Before District Court

Freeman Law on

In the first week of March 2025, two separate Texas tax cases were filed in Texas state district court. Each of these involves, among other claims, whether taxable security services should be rendered exempt when preempted...more

Husch Blackwell LLP

Executive Order Highlights Risks to Nonprofit Tax-Exempt Status

Husch Blackwell LLP on

President Trump’s executive order (EO) “Restoring Public Service Loan Forgiveness,” issued March 7, 2025, sets limits on student loan forgiveness under the Public Service Loan Forgiveness (PLSF) program. But the language used...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Will Congress Extend the Higher Estate Tax Exemption Before 2026?

As we approach the end of the first quarter of 2025, estate planners and their clients are closely monitoring developments in Washington, D.C. The scheduled sunset of the increased estate and gift tax exemption is now less...more

Offit Kurman

Death Tax Repeal Act

Offit Kurman on

On February 13, 2025, Republican lawmakers in Congress introduced the Death Tax Repeal Act, which aims to permanently eliminate the federal estate tax. Since 2015, various legislative efforts to repeal the estate, gift, and...more

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

Seward & Kissel LLP on

Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

ArentFox Schiff

Proposed Legislation Targets Nonprofits Supporting Immigrant Communities

ArentFox Schiff on

Proposed legislation introduced in the US Senate last week would deny tax-exempt status to certain organizations that support undocumented immigrants. The legislation would change the eligibility requirements for 501(c)(3)...more

Freeman Law

Colorado Religious Property Tax Exemption and UBI

Freeman Law on

Property owned by qualified religious organizations in Colorado may enjoy an exemption from state property tax. To enjoy exemption, the real and personal property must be owned and used “solely and exclusively for religious...more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Foodman CPAs & Advisors

Tax Preparation 2025 Useful Pointers

On 12/19/24, anticipating the 2025 filing season, the IRS published Tax Preparation 2025 Useful Pointers in IR-2024-311: Prepare to file in 2025: Get Ready for tax season with key updates, essential tips. As the 2025 filing...more

Proskauer - Tax Talks

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation

Proskauer - Tax Talks on

On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Estate Planning Strategies Before the 2025 Tax Sunset

The current federal estate tax exemption levels, introduced by the Tax Cuts and Jobs Act (TCJA) in 2018, have provided historically high federal estate tax exemptions. But this period of increased exemption is expected to...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

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The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

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