News & Analysis as of

UBTI Internal Revenue Code (IRC)

Seward & Kissel LLP

Private Equity Investment into NFL Teams: Tax and Business Considerations

Seward & Kissel LLP on

Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more

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

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

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

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...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

Troutman Pepper

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

Troutman Pepper on

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

BCLP

Proposed changes to group exemption letter program, UBTI ‘silo’ rules and more

BCLP on

IRS solicits public comments on proposed changes to group exemption letter program; will temporarily stop accepting requests for group exemption letters on June 17, 2020 - Notice 2020-36 contains a proposed revenue...more

Dickinson Wright

Exempt Organizations May Claim a Refund for Amounts Paid Under the TCJA's "Parking Lot Tax"

Dickinson Wright on

The Taxpayer Certainty and Disaster Tax Relief Act of 2019 (the “Relief Act”) has retroactively repealed a provision known as the “parking lot tax.” ...more

Groom Law Group, Chartered

Significant Developments Affecting VEBAs – Final IRS Rules Clarify Unrelated Business Taxable Income (“UBTI”) Issues But Renew...

In December, the IRS/Treasury (“IRS”) published final rules addressing how employers that fund health and welfare benefits through a VEBA (i.e., a voluntary employees’ beneficiary association described in Section 501(c)(9) of...more

Williams Mullen

New Parking Expense Rules for Taxable Employers and Tax-Exempt Organizations

Williams Mullen on

The Internal Revenue Service issued guidance last December to help employers that own or lease employer parking facilities or reimburse employees for parking expenses to navigate the recent change to the parking expense...more

Blank Rome LLP

Treasury Department Issues Guidance on Tax Treatment of Qualified Transportation Fringe Benefits

Blank Rome LLP on

The Treasury Department recently published guidance on determining the amount of qualified transportation fringe benefit expenses that are nondeductible and, for tax-exempt organizations, the amount that should be treated as...more

Proskauer - Not for Profit/Exempt...

Inclusion of Qualified Transportation Fringe Benefits in UBTI: Guidance, Relief, and Rumors of Possible Repeal

December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the “Code”), which requires tax-exempt employers to increase their unrelated business taxable income (“UBTI”) by...more

A&O Shearman

IRS Issues Guidance Affecting Tax-Exempt Investments in Private Equity Funds

A&O Shearman on

Under the Tax Cuts and Jobs Act (TCJA, December 22, 2017), tax-exempt investors must now calculate unrelated business taxable income (UBTI) separately with respect to each trade or business. As a result, a deduction from one...more

Morgan Lewis

IRS Issues Guidance on Calculating UBTI Under New Section 512(a)(6)

Morgan Lewis on

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

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

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Poyner Spruill LLP

Shorts on Long Term Care - May 2018 - News for the North Carolina LTC Community

Poyner Spruill LLP on

Finding and Fixing Your Own Noncompliance - During the 2016 Legislative Session, the N.C. Assisted Living Association (NCALA) was instrumental in bringing about passage of House Bill 667 which modified existing law on...more

Eversheds Sutherland (US) LLP

Highlighting itemized deduction limitations for private BDC investors

The Tax Cuts and Jobs Act (the Act), signed into law on December 22, 2017, amplifies the effects of certain deduction limitations as they apply to US-taxpaying individuals and other non-corporate investors in private business...more

Dechert LLP

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

Dechert LLP on

The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

King & Spalding

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

King & Spalding on

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

Holland & Knight LLP

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Holland & Knight LLP on

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

McGuireWoods LLP

IRS Provides Guidance on New Form 5500 Compliance Questions

McGuireWoods LLP on

The Internal Revenue Service (IRS) has provided clarification regarding new “compliance questions,” principally for retirement plans, that appear on the 2015 Forms 5500 and 5500-SF. These questions should not be answered....more

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

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

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