If tax-exempt entities invest in energy projects through partnerships, careful consideration should be given to allocations under the respective partnership arrangements to avoid any detrimental impact on the eligibility of the energy property’s basis for ITC and accelerated depreciation
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Tax Planning; Tax Minimization
Paid student-athletes: Tax implications for universities and donors
The taxation of Division I college sports may change once universities begin paying athletes directly, which will be permitted under a settlement of antitrust litigation against the NCAA and major collegiate athletic conferences. This article discusses some of the yet-to-be-resolved tax issues for schools and donors.
Planning for private foundation grantmaking
Private foundations can plan their grantmaking for optimal impact while complying with Sec. 4942 rules on required distributions. Strategies can help foundations support large charitable projects, preserve the value of their assets, and enhance long-term grantmaking capacity.
Private foundations’ distributions to and from nonpublic charities
Two recently published IRS letter rulings provide helpful informal guidance for private nonoperating foundations, particularly ones that receive and/or make grants from or to other private foundations.
Scholarship grants awarded by private foundations
As long as certain rules are followed, scholarship grants can be nontaxable to both the exempt private foundations granting them and the recipients of the grants.
Sales tax considerations for exempt organizations
Exempt organizations often dedicate resources to complying with federal tax laws but may not recognize the complexity of state and local sales and use taxes.
Excise tax on excess remuneration of covered employees of tax-exempt organizations
The IRS issued final regulations on the excise tax on excess remuneration over $1 million paid by tax-exempt organizations, finalizing proposed regulations with a few changes in response to comments.
Final rules on exempt organization excess remuneration
The IRS issued final regulations on the excise tax on excess remuneration over $1 million paid by tax-exempt organizations, finalizing proposed regulations with a few changes in response to comments.
Tax-exempt trusts: New guidance on Sec. 199A deduction
The IRS posted informal guidance on its website to explain how trusts that file Form 990-T and have unrelated business income can claim the deduction.
Charitable contribution procedures updated
The IRS issued new procedures for contributions to charitable organizations, including rules for when donors can rely on the information about an organization’s tax-exempt status on the IRS database Tax Exempt Organization Search.
Executive compensation planning for tax-exempt organizations
The TCJA added new Sec. 4960, which imposes an excise tax on tax-exempt organizations that pay excessive compensation.
Bunching charitable donations after the new tax law
A potential side effect of fewer taxpayers itemizing their deductions is that these taxpayers may choose to reduce or eliminate charitable contributions.
Contributions to quasi-governmental public-private partnerships
This article describes the requirements for an organization to meet Sec. 115(1).
What proposed regulations on the fractions rule mean for tax-exempt organizations
Proposed regulations could present tax-saving opportunities for qualified organizations that invest in partnerships.
IRS Withdraws Controversial Charitable Donation Rules
The IRS withdrew proposed regulations that would have allowed charities to file information returns with the IRS and donors instead of providing contemporaneous written acknowledgments of charitable donations.
Controversial Charitable Donation Rules Withdrawn
The IRS announced that it is withdrawing proposed regulations released last September that would have allowed charities to file information returns with the IRS and donors instead of providing contemporaneous written acknowledgments of charitable donations.
IRS to Implement Donee Reporting for Charities
The IRS will develop a specific-use information return for donee reporting.
Charities Would Be Permitted to Issue Information Returns to Donors
Charities will be allowed to file information returns instead of providing contemporaneous written acknowledgment of charitable donations under proposed regulations issued by the IRS.
Sec. 631(b) and the Taxation of Standing Timber Sales
Under Sec. 631(b), gains or losses from the sale of standing timber are considered gains and/or losses from the sale of business use property.
IRS Permits Charitable Contributions to Single-Member LLCs
The IRS explained that contributions to disregarded SMLLCs wholly owned and controlled by a U.S. charity will be treated as if made directly to the U.S. charity.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
