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 have been a major fan of Afro-Cuban (Salsa) and Brazilian Bossa Nova music since high school. Most of you know by now that I grew up in the Panama Canal Zone. By the time I got to West Point in the summer of 1978, it was...more
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
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
The US Department of the Treasury and the Internal Revenue Service issued its most recent Priority Guidance Plan Joint Statement (the Plan) on November 4, 2022. The Plan details more than 200 priorities for the 12-month...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
Since the enactment of the unrelated business income tax in 1950, section 512(b)(6)[1] and its predecessor allowed organizations subject to the unrelated business income tax (UBIT) to use the net operating loss (NOL)...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
The Internal Revenue Service ("IRS") has issued FAQs clarifying the net operating loss (“NOL”) carryback rules under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) as they apply to tax-exempt...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
On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more
The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) issued proposed regulations (REG-106864-18) addressing the so-called “silo” rule under Section 512(a)(6) of the Internal Revenue Code,...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
On April 23, 2020, the IRS and the Treasury Department released Proposed Regulations that provide guidance for how tax-exempt organizations (“EOs”) conducting multiple unrelated trades or businesses can 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
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 real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more
On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more
The IRS reminds Form 990-T Corporate Filers of new tax law provisions that could affect the tax rate applicable to their UBTI. Specifically, fiscal 2017 corporate filers should apply a blended rate to their UBTI for the...more
On January 18, 2019, the Internal Revenue Service (IRS) issued final regulations implementing the new pass-through income deduction for qualified business income (QBI) received from pass-through entities (such as sole...more
Thousands of nonprofits that provide parking benefits for their employees are subject to a new income tax on those benefits and have only weeks to avoid or minimize that tax liability for 2018. ...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
Do you provide parking for your employees? If so, take note: the expense has gone up (and, for tax-exempt employers, may now result in additional tax liability!)....more