Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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