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Tax Planning Excise Tax Internal Revenue Service

McDermott Will & Emery

Weekly IRS Roundup August 5 – August 9, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more

Gray Reed

IRS Targets Charitable Remainder Annuity Trusts (CRATs) as Listed Transactions

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On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions.  For those unaware of the listed transaction rules, such a designation would...more

Cadwalader, Wickersham & Taft LLP

IRS Releases Proposed Donor-Advised Fund Regulations

The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and...more

McGuireWoods LLP

Donor Advised Funds: Proposed Regs Offer Guidance, But Leave Big Questions Unanswered

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For the past 16 years, the U.S. Department of the Treasury’s Office of Tax Policy and the Internal Revenue Service’s joint Priority Guidance Plan has included the issuance of regulations relating to donor advised funds (DAFs)...more

A&O Shearman

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

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Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

McDermott Will & Emery

Weekly IRS Roundup January 17 – January 20, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more

McDermott Will & Emery

Weekly IRS Roundup December 19 – December 23, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 19, 2022 – December 23, 2022...more

Freeman Law

Tax Court in Brief | Couturier v. Commissioner | Taxation of Excess Contributions from IRA

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Tax Litigation: The Week of July 4th, 2022, through July 8th, 2022 Barrington v. Commissioner, T.C. Memo. 2022-68 | July 6, 2022 | Buch, J.| Dkt. No. 1781-14 Wolpert v. Commissioner, T.C. Memo. 2022-70 | July 7, 2022 |...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

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More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Freeman Law

Bankruptcy and IRC Section 4980H

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The recent bankruptcy case of In re Creative Hairdressers, Inc. et al, Case Nos. 20-14583 and 20-14584 (jointly administered) (Bankr. D. Md., March 3, 2022) involved the intersection of IRC section 4980H‘s employer shared...more

Freeman Law

Private Foundations, Taxable Expenditures, and Excise Taxes: IRS Issues Guidance

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On March 1, 2022, the IRS published its 129-page Exempt Organizations Technical Guide TG 62 Excise Taxes on Taxable Expenditures. While not authoritative or controlling, the guidance addresses in great detail the definitions...more

Freeman Law

IRS Issues Guidance on Self-Dealing Rules for Private Foundations

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IRS Issues Guidance on Self-Dealing Rules for Private Foundations - On March 1, 2022, the IRS published its 128-page Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941. While not...more

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

Take A Chance on Me! – Tax Planning During the Biden Administration

I have been posting my articles on JD Supra since August 2012. I am grateful to JD Supra for helping me to spread the tax gospel of Nowotny to readers. As of today, my articles have had 523,887 views. If my Mom and Dad (of...more

Proskauer - Not for Profit/Exempt...

Final Regulations on Executive Compensation Excise Tax (Section 4960) Carries Forward Most Concepts from Proposal

On January 19, 2021 the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published in the Federal Register Final Regulations (the “Final Regulations”) interpreting the excise tax under Section...more

Cozen O'Connor

New Guidance on Tax Holiday Suspension for Air Transportation Federal Excise Tax

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As previously reported, one of the benefits from the Coronavirus Aid, Relief, and Economic Security (CARES) Act was that the 7.5 percent air transportation federal excise tax (FET) that applies to commercial operations,...more

Groom Law Group, Chartered

Proposed Section 4960 Excise Tax Rules for Tax-Exempts: Highlights and Key Features

The Treasury Department (the “Department”) and Internal Revenue Service (“IRS”) recently released detailed proposed rules (the “Proposed Regulations”) interpreting Section 4960 of the Internal Revenue Code (the “Code”). 85...more

Morgan Lewis

IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations

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The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more

Seyfarth Shaw LLP

Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance

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Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more

Cozen O'Connor

IRS Issues Proposed Regulations for Tax on Nonprofit Executive Compensation

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The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

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• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more

Seyfarth Shaw LLP

Good News / Bad News: The IRS has Released Interim Guidance Regarding the New Excess Compensation Excise Tax Applicable to...

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Just in time for the New Year and notwithstanding the government shutdown, on December 31, 2018, the Internal Revenue Service (“IRS”) issued Notice 2019-09 (the “Notice”), which provides interim guidance on the new excise tax...more

Bricker Graydon LLP

TCJA excise tax on excess executive compensation for nonprofits

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Beginning with the 2018 tax year, nonprofit organizations that pay their top executives more than $1 million per year are subject to a new 21 percent excise tax. ...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Fisher Phillips

HSA Limit Changes

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Every year, the IRS announces the annual limits for various types of employee benefits, such as Health Savings Accounts (HSAs). The IRS has already changed the 2018 annual limits for HSAs twice this year, which may have...more

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