Fraud Risks at Nonprofit Organizations - Part 1
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
REFRESH Nonprofit Basics: Overview of Nonprofit Charitable Organization Types: Corporation, LLC, Trust, Association and Fiscal Sponsorship
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
REFRESH: Loot and Private Foundation Rules – Part 2
REFRESH: Loot and Private Foundation Rules – Part 1
IRS Dirty Dozen Warnings on Charitable Scams
California Regulation of Charitable Fundraising Platforms Part 2 - Reporting Due Diligence, Recordkeeping, and Disclosure Rules
California Regulation of Charitable Fundraising Platforms: Part I - Definitions
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Basics: Unpacking Prudent Investments, PRIs and MRIs
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Exceptions to the DAF Definition Under the Proposed Regulations
New Proposed Regulations Defining Donor Advised Fund Terms
In the Weeds With New Supporting Organization Regulations
The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more
Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s (“DOJ”) first criminal indictment related to syndicated conservation easements. The trial is...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more
Summary: This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
Tax Litigation: The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
For over 15 years, I have represented tax-exempt charitable entities—mega, large, medium, small, and everything in between. Through that experience, I have seen the best of times and the worst of times (and everything in...more
Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Genecure, LLC v. Comm’r, T.C. Memo 2022-52 | May 23, 2022 | Jones, J. | Dkt. No. 14916-15. Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J....more
Tax Litigation: The Week of March 21, 2022, through March 25, 2022 Oxbow Bend, LLC v. Comm’r, T.C. Memo. 2022-23 | March 21, 2022 |Lauber, J. | Dkt. No. 12718-19 Short Summary: This case involves a charitable contribution...more
Since January of 2020, over 175,000 COVID-19 related GoFundMe campaigns were created, raising more than $416 million. While donors may be feeling charitable, they should know that their contributions are likely not...more
In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more
Tax season is right around the corner, but good tax planning takes place all year long! See below for some of our favorite tips and tricks. These cover a variety of areas including charitable giving, estate tax exemptions,...more
As 2019 comes to a close, while most people are busy making holiday plans, dutiful tax advisors and financial planners are burning the midnight oil to minimize their clients’ tax bills that will be due in a few short months....more
You may be happy that a refund is coming, or you may be steamed at the amount of taxes you had to pay. Regardless, the experience you had for the 2017 tax season likely will be significantly different from the 2018 tax...more
On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more
Last week, Representative Mike Kelly (R) of Pennsylvania and Representative Mike Thompson (D) of California introduced the Charitable Conservation Easement Program Integrity Act of 2017 as H.R. 4459. The Act is simple;...more
The use of a limited liability company (LLC) by Mark Zuckerberg and his wife Priscilla Chan as the vehicle for advancing of “philanthropic, public advocacy, and other activities for the public good” has recently received a...more
When Mark Zuckerberg recently announced that he was giving away up to 99 percent of his Facebook shares (valued at approximately $45 billion), he was severely criticized for it. Zuckerberg and his wife created the Chan...more