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Treat People With Kindness (But Don’t Forget Secular Tax Law)

For tax-exempt public charities, benevolent acts must be considered within the guardrails of section 501(c)(3) of the Internal Revenue Code. To enjoy tax-exemption as an organization described in Section 501(c)(3), the...more

Correction to APA Non-Compliance | IRS Issues Proposed Regulations for Syndicated Conservation Easements

On December 6th, the IRS proposed regulations (and comment period for same) that would require participants and promoters of syndicated conservation easement transactions to make certain disclosures relating conservation...more

Is a Mandated Gift Deductible as a Charitable Contribution? A Review of The Meaning of “Gift” in IRC 170.

For over 15 years, I have represented tax-exempt charitable entities—mega, large, medium, small, and everything in between. Through that experience, I have seen the best of times and the worst of times (and everything in...more

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

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

Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions

Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions - On March 11, 2022, the Joint Committee on Taxation published its 49-page report (the “Report”) relating to the federal tax treatment of...more

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code...

Section 6751(b)(1) of the Internal Revenue Code provides that “[n]o penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate...more

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