News & Analysis as of

UBTI Tax Cuts and Jobs Act

Troutman Pepper

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

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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

Dorsey & Whitney LLP

Top Three Current Revenue Stream Considerations for Tax-Exempt Organizations Providing Elder Care

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Current economic conditions have put additional strain on organizations across the health care spectrum in unprecedented ways. However, along with new challenges, both market conditions and new guidance from the Internal...more

Snell & Wilmer

CARES Act NOL Carryback Rules for Tax-Exempt Organizations with UBTI

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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

Proskauer - Tax Talks

Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments

Proskauer - Tax Talks on

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

Proskauer Rose LLP

Proposed Regulations Provide Guidance to Exempt Organizations on Identifying Separate Unrelated Trade or Businesses

Proskauer Rose LLP on

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

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations Address Income Aggregation Rules for Tax-Exempt Organizations

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

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

BCLP

Form 990-T Fiscal Year 2017 Corporate Filers Apply Blended Rate to Unrelated Business Taxable Income (UBTI) for Entire Taxable...

BCLP on

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

Snell & Wilmer

The Pass-Through Income Deduction for Charitable Remainder Trusts

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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

Bracewell LLP

From Sunrise to Sunset: Phasing-Out the Renewable Energy Tax Credits

Bracewell LLP on

While corporate tax reform and reduced tax rates were the hallmark of sweeping 2017 legislation (the Tax Cuts and Jobs Act, or TCJA), and thus the focus of the media and tax professionals, the renewables industry was largely...more

Troutman Pepper

Addition of UBTI Siloing Rules Creates New Challenges for Tax-Exempt Organizations - Tax Update Volume 2019, Issue 2

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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

Poyner Spruill LLP

Recent IRS Guidance Details Cost of Providing Employee Parking

Poyner Spruill LLP on

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

Jackson Lewis P.C.

Interim IRS Guidance Addressing Taxation Impact Of Transportation And Parking Fringe Benefits Creates Planning Opportunities For...

Jackson Lewis P.C. on

In Notice 2018-99, the Internal Revenue Service sets forth interim guidance for taxpayers to determine parking expenses for qualified transportation fringes (QTFs) that are nondeductible and for tax-exempt organizations to...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

McGuireWoods LLP

Tax Law Changes Complicate Tax-Exempt Organizations’ Attempts to Calculate UBTI

McGuireWoods LLP on

Charities and other exempt organizations face higher taxes, more complex returns and tough investment decisions under new unrelated business income tax rules effective for 2018. Despite recent guidance from the Internal...more

Bracewell LLP

Bracewell Tax Report - October 2018

Bracewell LLP on

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

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

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

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

If It’s Monday, It Must Be Malta! The Benefits of Malta Pension Schemes for U.S. Taxpayers

Since the passage of the Tax Cuts and Jobs Act (TCJA) on December 22, 2017, interest in the use of qualified retirement plans has increased. However, qualified retirement plans are not without their limitations and...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

Troutman Pepper

Update on Charitable Tax Planning: Guidance on Donor-Advised Funds and Overview of New UBTI Rules - Tax Update, Volume 2018, Issue...

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Donor-Advised Funds There are many areas in which guidance is lacking concerning the operation of a donor-advised fund (DAF). In Notice 2017-73, the IRS provided interim guidance on two specific issues and requested comments...more

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