News & Analysis as of

Unrelated Business Income Tax

Rivkin Radler LLP

Hospital As Educational Organization? The Mayo Clinic’s UBIT Refund Claim

Rivkin Radler LLP on

Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more

Freeman Law

Is Your Trade Associations prepared for IRS audit? IRS Issues Technical Guidance for 501(c)(6) Organizations

Freeman Law on

On September 16, 2022, the IRS published its Exempt Organizations Technical Guide TG 6 IRC 501(c)(6) Business League (“TG6”). TG6 discusses tax exemption of business leagues, chambers of commerce, real estate boards, and...more

Freeman Law

Can a Nonprofit Fundraise for Another Nonprofit? Legal and Tax Considerations.

Freeman Law on

I’ve served as outside general counsel for nonprofit organizations across the nation for over 15 years. This question is re-occurring. So, I thought I would blog a little about it. Not legal or tax advice; just legal and tax...more

Freeman Law

Tax Exemption and Unrelated Business Income Rules (UBIT): “Substantially Related” (Part 3 of 3)

Freeman Law on

This Insights blog is Part 3 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more

Freeman Law

Tax Exemption and Unrelated Business Income Tax (UBIT): Rules, Modifications and Exceptions (Part 2 of 3)

Freeman Law on

This Insights blog is Part 2 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more

Freeman Law

Tax Exemption and Unrelated Business Income Tax (UBIT): The Framework (Part 1 of 3)

Freeman Law on

This Insights blog is Part 1 of a 3-Part series that provides a focused overview of the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal...more

BCLP

IRS Revising Form 1024; New Technical Guides; Information for LLCs Applying for 501(c)(3) Tax-Exempt Status; Revised Form 4506-A;...

BCLP on

IRS Revising Form 1024 to Allow for Electronic Submission - As part of an ongoing effort to improve service for the tax-exempt community, the IRS is revising Form 1024, Application for Recognition of Exemption Under...more

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

TAKE A CHANCE ON ME! Part II

Embracing the Magic of Private Placement Life Insurance (PPLI) and Private Placement Variable Annuities (PPVA) - I am happy to be back from my writing hiatus. In retrospect I am not really certain what the reason was for...more

McDermott Will & Emery

Eighth Circuit Holds the Mayo in Tax Regulation Invalidity Case

McDermott Will & Emery on

In the latest tax regulation deference case, the Eighth Circuit provided guidance to taxpayers and tax practitioners on the “analytical path” to resolve the question of whether a tax regulation is a valid interpretation of...more

Lathrop GPM

IRS Releases New Proposed UBTI “Siloing” Regulations with Slightly More Flexibility, Guidance for Nonprofits

Lathrop GPM on

On April 23, 2020, the IRS published new proposed regulations with guidance on how nonprofits should calculate their unrelated business taxable income, or UBTI, for separate trades or businesses. This long-awaited guidance,...more

Proskauer - Not for Profit/Exempt...

IRS Provides Guidance on Unrelated Business Income Tax Refunds

On Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax,” with...more

Morgan Lewis

IRS Instructs Nonprofits on How to Claim Parking Tax Refund

Morgan Lewis on

On December 20, 2019, Congress retroactively repealed Internal Revenue Code (IRC) Section 512(a)(7), which had increased unrelated business taxable income by amounts paid or incurred for qualified transportation fringes....more

Groom Law Group, Chartered

SECURE Act and Spending Bills – Impact on Plan Sponsors

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”), the largest package of retirement system reforms in over a decade, was enacted on December 20, 2019.  Many of the provisions in the...more

Proskauer - Not for Profit/Exempt...

Repeal of Unrelated Business Income Tax on Qualified Transportation Fringe Benefits

Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”...more

Proskauer - Employee Benefits & Executive...

New IRS Guidance for Tax-Exempt Entities Funding Employee Benefits

The IRS recently released a final regulation clarifying how voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs) should calculate unrelated business taxable income. VEBAs...more

Farrell Fritz, P.C.

Not-for-Profits & the Tax Cuts and Jobs Act of 2017

Farrell Fritz, P.C. on

The new federal tax law that went into effect at the beginning of this year, the “Tax Cuts and Jobs Act of 2017” (Tax Act), will affect almost every type of individual and business in the country, and not-for profit entities...more

Seyfarth Shaw LLP

New Guidance For Nonprofits And The Tax On Parking And Public Transit Benefits

Seyfarth Shaw LLP on

Two recent Treasury Notices provide interim guidance to nonprofits trying to calculate (or seeking to avoid) the tax they may have to pay for the provision of certain parking and public transit benefits to their employees,...more

Robinson & Cole LLP

IRS Issues Interim Guidance on Qualified Transportation Fringe Benefits

Robinson & Cole LLP on

The IRS issued two pieces of interim guidance with respect to the new treatment of qualified transportation fringe benefits following the changes made by the Tax Cuts and Jobs Act (Tax Act). The Tax Act required parking...more

Bricker Graydon LLP

New guidance: Calculation of non-deductible parking expenses and deemed unrelated business income

Bricker Graydon LLP on

The Internal Revenue Service recently issued Notice 2018-99 to address changes in the Internal Revenue Code included in the Tax Cuts and Jobs Act (TCJA). ...more

Polsinelli

IRS Releases Interim Guidance for Exempt Organizations on New Unrelated Business Income Tax Rules

Polsinelli on

The IRS and Treasury Department recently released new guidance for calculating the tax on unrelated business income (“UBI”) activities of tax-exempt organizations with more than one UBI activity. With the passage of the 2017...more

Bricker Graydon LLP

New guidance on the Tax Cuts and Job Act’s unrelated business taxable income changes

Bricker Graydon LLP on

Recently, the Internal Revenue Service (IRS) released Notice 2018-67 to provide interim guidance to exempt organizations in calculating unrelated business taxable income (UBI)....more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

Foster Garvey PC on

Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The 2017 Tax Cuts and Jobs Act: A Pandora’s Box for Higher Education

The enactment of the Tax Cuts and Jobs Act of 2017 has raised a number of potential issues for institutions of higher education. Due to this significant impact, institutions need to study the Tax Act and plan appropriately....more

BCLP

The Good, the Bad, and the Tax-Exempt Organization: The New Tax Bill’s Effect on Benefits and Compensation Offered by Institutions...

BCLP on

On December 22, President Trump signed “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018” (“Bill”) into law. The Bill was previously named the...more

Holland & Knight LLP

Tax Reform and the Potential Impact on Tax-Exempt Organizations

Holland & Knight LLP on

Both the Trump Administration and key leadership in the U.S. House of Representatives and Senate are continuing their focus on tax reform. Although details are being withheld until the Republican leadership in the House,...more

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