Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more
On September 16, 2022, the IRS published its Exempt Organizations Technical Guide TG 6 IRC 501(c)(6) Business League (“TG6”). TG6 discusses tax exemption of business leagues, chambers of commerce, real estate boards, and...more
I’ve served as outside general counsel for nonprofit organizations across the nation for over 15 years. This question is re-occurring. So, I thought I would blog a little about it. Not legal or tax advice; just legal and tax...more
This Insights blog is Part 3 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more
This Insights blog is Part 2 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more
This Insights blog is Part 1 of a 3-Part series that provides a focused overview of the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal...more
IRS Revising Form 1024 to Allow for Electronic Submission - As part of an ongoing effort to improve service for the tax-exempt community, the IRS is revising Form 1024, Application for Recognition of Exemption Under...more
On April 23, 2020, the IRS published new proposed regulations with guidance on how nonprofits should calculate their unrelated business taxable income, or UBTI, for separate trades or businesses. This long-awaited guidance,...more
On Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax,” with...more
On December 20, 2019, Congress retroactively repealed Internal Revenue Code (IRC) Section 512(a)(7), which had increased unrelated business taxable income by amounts paid or incurred for qualified transportation fringes....more
Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”...more
The IRS recently released a final regulation clarifying how voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs) should calculate unrelated business taxable income. VEBAs...more
The new federal tax law that went into effect at the beginning of this year, the “Tax Cuts and Jobs Act of 2017” (Tax Act), will affect almost every type of individual and business in the country, and not-for profit entities...more
The IRS issued two pieces of interim guidance with respect to the new treatment of qualified transportation fringe benefits following the changes made by the Tax Cuts and Jobs Act (Tax Act). The Tax Act required parking...more
The Internal Revenue Service recently issued Notice 2018-99 to address changes in the Internal Revenue Code included in the Tax Cuts and Jobs Act (TCJA). ...more
The IRS and Treasury Department recently released new guidance for calculating the tax on unrelated business income (“UBI”) activities of tax-exempt organizations with more than one UBI activity. With the passage of the 2017...more
Recently, the Internal Revenue Service (IRS) released Notice 2018-67 to provide interim guidance to exempt organizations in calculating unrelated business taxable income (UBI)....more
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
Proskauer’s 21st Annual Trick or Treat Seminar was held on Thursday, October 27. The Seminar discussed: Best Practices for Document Retention: One Size Does Not Fit All...more
Those responsible for managing a private foundation’s investment assets may not always understand the unique fiduciary and tax constraints imposed on private foundations and their managers by both state and federal law....more
In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more
Every January, the IRS releases a series of revenue procedures detailing how organizations can obtain private letter rulings and determinations and listing issues on which the IRS will not rule during the coming year. This...more
On October 26, 2015, the IRS released final regulations under Sections 141 and 145 of the Internal Revenue Code concerning the use of property financed with tax-exempt bond proceeds. The bulk of the new regulations fill a...more
On July 11, 2014, the IRS released a Technical Advice Memorandum ("TAM") finding that a tax-exempt hospital's income from the performance of laboratory services for non-patients was not subject to the unrelated business...more