News & Analysis as of

UBIT

Farella Braun + Martel LLP

Navigating Charitable Bequests: Risks and Rewards for Early Planning

Charitable bequests are an essential aspect of philanthropic planning for high net worth individuals. When engaging in conversations with philanthropic clients, it is crucial to help them determine suitable assets for...more

Rivkin Radler LLP

Hospital As Educational Organization? The Mayo Clinic’s UBIT Refund Claim

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Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Nonprofit Sector Compliance Conference - May 24th, 9:00 am - 4:00 pm CDT

Get the support you need to properly manage key nonprofit compliance challenges - Nonprofit organizations often find themselves vulnerable to unique fraud and conflict of interest concerns. This one-day virtual conference...more

Williams Mullen

[Webinar] Spring Tax Forum 2021 - June 8th, 11:00 am - 12:00 pm EDT

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Please join us for the Spring Tax Forum to be held virtually on Tuesday, June 8, 2021. Register to join Jenny Connors, Philip Delano, Marie Yascko-Rosado and Kevin Bender for an informative discussion on the latest updates in...more

BCLP

Expanded Tax Benefits for Giving to Charity, 2020 Forms 990-T and 4720 Revisions and Other News

BCLP on

Year-end reminder: Expanded tax benefits help individuals and businesses give to charity during 2020 - The IRS today explained how expanded tax benefits can help both individuals and businesses give to charity before the...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Nonprofit Sector Compliance Conference - November 5th, 9:20 am - 3:30 pm CST

The charitable organization sector faces many compliance challenges, including: - unique tax exemption issues - fundraising registration and related issues - privacy and data security - complex reporting...more

Groom Law Group, Chartered

IRS Proposes Rules on UBIT Changes Affecting Benefit Plan Investors

A pension or welfare plan’s investment in a private equity or real estate partnership, among other investment funds, may give rise to “unrelated business income tax” (“UBIT”)....more

Locke Lord LLP

The Midstream REIT; New Private Letter Ruling Guidance from the IRS May Enhance REIT Investment Option for Midstream Energy Assets

Locke Lord LLP on

Private letter ruling 201907001 (the “PLR”), recently issued by the Internal Revenue Service (“IRS”), indicates that a midstream energy company may be able to organize as a real estate investment trust (“REIT”) under Section...more

Perkins Coie

IRS Issues Guidance on Prior Year Parking Tax Refunds or Credits for Tax-Exempt Organizations

Perkins Coie on

On January 21, 2020, the Internal Revenue Service (IRS) released guidance for tax-exempt organizations on how they may obtain a refund or credit for prior year unrelated business income tax (UBIT) incurred for qualified...more

BCLP

Form 1023 Revisions and Required Electronic Submission

BCLP on

The IRS is revising Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions, to help charities apply for 501(c)(3) tax-exempt status. Effective January...more

McGuireWoods LLP

IRS Issues Guidance on Filing Refund Claims Related to the Repeal of the “Parking Tax” on Nonprofits

McGuireWoods LLP on

The Internal Revenue Service posted informal guidance on its website to assist nonprofits claiming refunds for previously paid unrelated business income tax associated with the “parking tax” on nonprofits, which was repealed...more

Morgan Lewis

IRS Instructs Nonprofits on How to Claim Parking Tax Refund

Morgan Lewis on

On December 20, 2019, Congress retroactively repealed Internal Revenue Code (IRC) Section 512(a)(7), which had increased unrelated business taxable income by amounts paid or incurred for qualified transportation fringes....more

McGuireWoods LLP

Parking Tax on Nonprofits Retroactively Repealed and Tax Rate for Private Foundations Changed

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Last month, Congress retroactively repealed the provision of the 2017 Tax Act that imposed unrelated business income tax on nonprofits that provided qualified transportation fringe benefits to employees....more

Ballard Spahr LLP

SECURE Act In; Cadillac Tax Out: The Spending Act Makes Serious Changes to Benefits Rules

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Below is a summary of those key provisions. I. SECURE Act The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act, H.R. 1994) is arguably the most significant and comprehensive retirement saving...more

King & Spalding

Tax-Exempt Mayo Clinic Awarded $11.5M UBIT Refund, Invalidating Treasury Regulations In the Process

King & Spalding on

In a recent taxpayer win, the United States District Court for the District of Minnesota granted summary judgment in an $11.5 million refund claim brought by the Mayo Clinic (“Mayo”) on the basis that certain Treasury...more

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more

Dickinson Wright

Qualified Transportation Fringe Benefits No Longer Deductible for Employers

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In the past, employers have been able to deduct expenses related to “qualified transportation fringe benefits” (“QTFBs”) such as qualified parking, transit passes, transportation in commuter highway vehicles, or qualified...more

Kelley Drye & Warren LLP

Tax Cuts and Jobs Act: Tax-Exempt Organizations

As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act (the “Act”), signed into law at the end of 2017, contains significant changes affecting the tax treatment of certain fringe benefits and executive...more

Hogan Lovells

Three new acts change tax and employee benefit rules and might require employer action

Hogan Lovells on

Congress and the Administration have been busy recently, enacting not only the "Tax Cuts and Jobs Act" or "TCJA" on December 22, 2017, but also a Continuing Resolution on January 23, 2018, and the Bipartisan Budget Act of...more

Pullman & Comley, LLC

ALERT: The Tax Cuts and Jobs Acts Provisions Apply to Colleges and Universities

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Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more

Pullman & Comley, LLC

Tax Cuts and Jobs Act

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Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more

Foley & Lardner LLP

Tax Reform: Provisions Directly Affecting Tax-Exempt Organizations

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he Tax Cuts and Jobs Act was signed into law on December 22, 2017. This tax reform law includes the following changes directly affecting nonprofit and tax-exempt organizations, and those who donate to them. A number of...more

Bond Schoeneck & King PLLC

Let’s BOND over the Tax Act Part II - The Higher Education Edition

In the spirit of accentuating the positive, there are a few bits of good news for colleges and universities in the Tax Act…as Mary Poppins might say, a spoonful (or three) of sugar to help the medicine go down. Unfortunately,...more

Obermayer Rebmann Maxwell & Hippel LLP

Considerations for Tax-Exempt Organizations under the New Tax Cuts and Jobs Act

The recent Tax Cuts and Jobs Act (“TCJA”) is the largest tax code rewrite in several decades and includes significant changes for the nonprofit sector. Three major changes that raise complex issues for tax-exempt...more

Pillsbury Winthrop Shaw Pittman LLP

Key Tax Reform Issues for Nonprofit Membership Organizations/Associations

Associations avoided the harshest proposals but should be aware of several important new tax issues. Associations subject to unrelated business income tax can no longer use losses in one unrelated business to offset income...more

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