The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
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
On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more
As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more
Estate planning and wealth transfer professionals have their eyes on the sky as the future of federal estate taxation grows increasingly nebulous. Background - The federal gift and estate tax exemption is the amount...more
This article provides Corporate Transparency Act (CTA) guidance to tax-exempt organizations with subsidiaries. For a general overview of CTA compliance for nonprofit and tax-exempt organizations, please see Part 1: When to...more
The Corporate Transparency Act (CTA) took effect on January 1, 2024 and some U.S. nonprofits and tax-exempt organizations are still debating how the CTA applies to them. This article provides newly-formed and existing...more
Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...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
If the IRS challenges the tax-exempt status of a name, image, and likeness (NIL) collective, the collective must understand how best to respond. Our Federal Tax Group details what NIL collectives need to know to make the cut....more
June 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more
When considering compensation and benefits packages to lure and retain top executives or talent, nonprofit organizations, including universities and hospitals, are often at a disadvantage compared to their for-profit rivals....more
In a significant legislative shift, the Tax Cuts and Jobs Act of 2017 doubled the exemption amounts for estate, gift, and generation-skipping transfer taxes (collectively known as “Death Taxes”). As of 2024, the federal...more
As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
With the 2024 election cycle underway, it is important for exempt organizations to understand and comply with relevant restrictions on political campaign activities to safeguard their tax-exempt status and avoid triggering...more
The Corporate Transparency Act (the “CTA”) became effective on Jan. 1. The CTA’s goal is to reduce money laundering and other financial crimes by requiring the reporting of ownership and control information of businesses...more
The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more
In 2024, the federal estate, gift, and Generation Skipping Transfer tax exemption amount increased from $12.92 million to $13.61 million per individual (a combined $27.22 million for a married couple), representing an...more
As 2024 gets underway, the nonprofit sector will continue to face new challenges in addition to grappling with ongoing challenges that continue to impact the sector. Our interdisciplinary team, serving thousands of nonprofits...more
On two separate occasions in the first two months of 2024, members of Congress have invited IRS scrutiny of tax-exempt charitable organizations for activities that were perceived to be political lobbying. In January,...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
In September, Treasury announced forthcoming guidance that will clarify whether the limited partner exception applies to limited partners that actively participate in their businesses....more
Recent bills in the U.S. House of Representatives and Senate demonstrate legislators’ concerns about several issues related to nonprofits, including: (1) admissions practices at institutions of higher education; (2)...more
The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more
ArentFox Schiff’s clients report being inundated with notices from registered agents and other service providers to comply with the Corporate Transparency Act (CTA), a new law that will require many existing and newly formed...more