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Tax Exempt Entities Tax Liability

ASKramer Law

Energy Tax Credits for a New World Part VIII: Monetizing Energy Tax Credits

ASKramer Law on

What is “monetization”? Monetization is the process by which property is converted into money or something else of value. In the context of the Inflation Reduction Act of 2022 (IRA), certain provisions can allow entities that...more

Farella Braun + Martel LLP

REFRESH: Loot and Private Foundation Rules – Part 2

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In this episode, we refresh EO Radio Show episode 22, the second of our two episodes exploring private foundation rules using commentary on the comic Apple TV+ series...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

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Here we are, solidly in the 2024 election year, and that means that private foundations need to refresh their understanding of election year issues for organizations...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy...

Welcome to EO Radio Show - Your Nonprofit Legal Resource. As most listeners are undoubtedly aware, 2024 is an election year, and that means that charities and private foundations need to refresh their understanding of...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I’m Cynthia Rowland, and this is episode 66 of EO Radio Show. Happy New Year to all of you! As most listeners are undoubtedly aware, 2024 is an election year, and that...more

Freeman Law

Treat People With Kindness (But Don’t Forget Secular Tax Law)

Freeman Law on

For tax-exempt public charities, benevolent acts must be considered within the guardrails of section 501(c)(3) of the Internal Revenue Code. To enjoy tax-exemption as an organization described in Section 501(c)(3), the...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

Tax Court in Brief | XC Foundation v. Comm’r | Tax Court Jurisdiction and Corporate Capacity to Seek Relief

Freeman Law on

Summary: XC Foundation (“XC”) was incorporated in California in 2007. In 2008, the IRS issued XC a determination letter recognizing it as exempt from federal income tax under section 501(c)(3) and as a private foundation...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

Extra, Extra: IRS Division of Tax Exempt and Government Entities Releases FY2023 Program Letter

Freeman Law on

On November 4, 2022, the Tax Exempt and Government Entities division of the IRS (TE/GE) released its Fiscal Year 2023 Program Letter (2023 Program)....more

Freeman Law

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

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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

Freeman Law

Can a Nonprofit Fundraise for Another Nonprofit? Legal and Tax Considerations.

Freeman Law on

I’ve served as outside general counsel for nonprofit organizations across the nation for over 15 years. This question is re-occurring. So, I thought I would blog a little about it. Not legal or tax advice; just legal and tax...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 23, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...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

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

Freeman Law

The Tax Court in Brief - August 2021

Freeman Law on

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

Freeman Law

What is reasonable compensation for employees of an I.R.C. § 501(c)(3)? (Part 1)

Freeman Law on

One of the most important decisions a board determines is what constitutes reasonable compensation. The rules for this determination are robust and so are the taxes imposed for violations of the Internal Revenue Code and the...more

Stinson LLP

Are Airlines on the Hook for State and Local Taxes Addressing Homelessness?

Stinson LLP on

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

Seyfarth Shaw LLP

Fix a Decade of Document Errors? Yes You Can!

Seyfarth Shaw LLP on

Seyfarth Synopsis: In two months (on March 31, 2020), the window closes for 403(b) plan sponsors to take advantage of the unique opportunity to retroactively amend their 403(b) retirement plans to correct document errors...more

McDermott Will & Emery

Weekly IRS Roundup December 30, 2019 – January 3, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2019 – January 3, 2020. December 30, 2019: The IRS issued a news release announcing...more

Proskauer - Not for Profit/Exempt...

Repeal of Unrelated Business Income Tax on Qualified Transportation Fringe Benefits

Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”...more

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