Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
I have been a major fan of Afro-Cuban (Salsa) and Brazilian Bossa Nova music since high school. Most of you know by now that I grew up in the Panama Canal Zone. By the time I got to West Point in the summer of 1978, it was...more
I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...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
Since the enactment of the unrelated business income tax in 1950, section 512(b)(6)[1] and its predecessor allowed organizations subject to the unrelated business income tax (UBIT) to use the net operating loss (NOL)...more
On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) addressing the manner in which tax-exempt organizations calculate their...more
The Internal Revenue Service (IRS) and the US Department of the Treasury released proposed regulations on April 23 that provide guidance for calculating UBTI and make some important changes to the interim guidance the IRS...more
On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more
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