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Final Section 162(f) Regulations Set Forth Deductibility Rules for Payments Involving Government Investigations

Background - Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more

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

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

May 15 Deadline Approaching for New Excise Tax Triggered Even When Tax-Exempt Organizations Pay No Compensation

Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more

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

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

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

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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