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Tax Planning Tax Exempt Entities 501(c)(3)

Farella Braun + Martel LLP

Nonprofit Quick Tip: State Filings in North Carolina and South Carolina

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Episode 75 is the tenth in a series of Quick Tip episodes focusing on the details of state registration of nonprofit corporations. Today, Cynthia Rowland and Joe...more

Freeman Law

Section 501(c)(3) Dissected: IRS Issues Detailed Guidance on Exempt Purposes

Freeman Law on

On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more

Freeman Law

Yeah, Science! IRS Issues Guidance Section 501(c)(3) Scientific Organizations

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In the Netflix series, Breaking Bad, character Jesse Pinkman exclaimed, “Yeah, Science!!” as his meth-lab mentor, Walter White, displayed how chemistry can be used to hone their joint venture. While the activity in which they...more

Freeman Law

Adverse Rulings from the IRS Exempt Organizations Division. How Can Your Organization Learn from Others’ Mistakes?

Freeman Law on

On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more

Maynard Nexsen

Standards for Section 501(c)(3) Status of Limited Liability Companies

Maynard Nexsen on

The Internal Revenue Service (IRS) issued Notice 2021-56 - Standards for Section 501(c)(3) Status of Limited Liability Companies as its first attempt to set the standards for a limited liability company (LLC) to become a...more

Freeman Law

IRS Tax Exempt and Government Entities: A Summary of the Past Year

Freeman Law on

On January 6, 2022, the Tax Exempt and Government Entities (TE/GE) released its Fiscal Year 2021 Accomplishments Letter. Here is a summary below...more

Proskauer - Not for Profit/Exempt...

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

Miller Nash LLP

An Athlete's Guide to Philanthropy, Nonprofit Organizations, and Community Impact: Process and Pitfalls of Forming Nonprofit...

Miller Nash LLP on

As discussed in prior articles, there are several options for tax-incentivized giving, ranging from the informal and low-involvement to complex and highly involved structures. Many choose to adopt a more formal approach to...more

Miller Nash LLP

IRS Issues (and Seeks Comments on) Standards for Qualifying an LLC as a 501(c)(3) Entity

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Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently...more

Morgan Lewis

IRS to Organizations Seeking 501(C)(3) Exempt Status: Charitable Means Charitable

Morgan Lewis on

The Internal Revenue Service (IRS) on October 9 released a denial letter issued to an organization seeking exemption under Section 501(c)(3) to operate a program to “to deploy capital into projects that promote a social good...more

Polsinelli

IRS Attacks Impact Investing With Flawed Logic: A Critical Review of the IRS Argument

Polsinelli on

On October 9th, the Internal Revenue Service released Private Letter Ruling 202041009 (the “Ruling”), which, in what many in the nonprofit community would have expected to be a relatively straight-forward exemption approval...more

Polsinelli

IRS Ruling Takes Aim at Impact Investing

Polsinelli on

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more

WilmerHale

What Nonprofits Should Learn From AG Lawsuits Against NRA

WilmerHale on

On Aug. 6, New York Attorney General Letitia James and D.C. Attorney General Karl Racine brought blockbuster lawsuits against the National Rifle Association and the National Rifle Association Foundation, alleging that these...more

Saul Ewing LLP

Mayo Clinic Convinces Federal District Court (Minn.) That It Is an “Educational Organization” Entitled to Treat Its Debt-Financed...

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The Mayo Clinic is granted a tax refund of $11.5 million, claiming that the income, even though unrelated to its exempt purposes and debt-financed, is nevertheless exempt from tax since the Mayo Clinic qualifies as an...more

Seyfarth Shaw LLP

Understanding And Planning For The Excise Tax On Executive Compensation Paid By Tax-Exempt Employers

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In the past decade or so, the competition for executive talent in the tax-exempt sector of the United States economy has increased. Executives seldom begin and end their careers with the same organization and there is...more

Foley & Lardner LLP

New IRS Regulations for Mixed-Use Projects Financed With Tax-Exempt Bonds Have Practical Importance

Foley & Lardner LLP on

On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant...more

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