Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more
I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more
On April 23, the Treasury Department and the Internal Revenue Service (the "IRS") issued helpful proposed regulations under section 512(a)(6) of the Internal Revenue Code (the "proposed regulations"). Section 512(a)(6) was...more
On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) addressing the manner in which tax-exempt organizations calculate their...more
The Internal Revenue Service (IRS) and the US Department of the Treasury released proposed regulations on April 23 that provide guidance for calculating UBTI and make some important changes to the interim guidance the IRS...more
Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more
Hell of a Town- Ask most New Yorkers what New York City has in abundance and you’ll get responses that are as varied as the personalities to whom the question is put. Museums, restaurants, performing arts, college...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
With some exceptions, organizations subject to the unrelated business income tax under Section 511 that have more than one unrelated trade or business may rely on a “reasonable, good-faith interpretation of §§ 511 through...more
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
The Tax Cuts and Jobs Act, currently under consideration in the US House of Representatives and Senate, proposes fundamental changes to the US tax law affecting all sectors of the economy, including nonprofit organizations....more
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more
Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more
On February 6, 2014, the Internal Revenue Service (IRS) proposed new regulations for calculating the unrelated business taxable income (UBTI) of IRC section 501(c)(9) voluntary employees’ beneficiary associations (VEBA) and...more