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The Taxpayer Certainty and Disaster Tax Relief Act of 2019 (the “Relief Act”) has retroactively repealed a provision known as the “parking lot tax.”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