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Share on Twitter Share by Email Share Back to top The One Big Beautiful Bill Act (OBBBA) modifies the excise tax on net investment income of private colleges and universities under Internal Revenue Code (IRC) Section 4968....more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more
Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more
Good news to close out the year: The “Further Consolidated Appropriations Act, 2020” (H.R. 1865 - the “2020 Act”) retroactively repeals the much maligned tax on qualified transportation fringe benefits (the so-called “church...more
In-house counsel and human resources professionals at tax-exempt colleges and universities often face a variety of challenges when structuring, and determining obligations due under, severance arrangements. There are some key...more
IRS Notice 2019-09 provides guidance intended to help “applicable tax-exempt employers” determine whether compensation paid to their most highly compensated employees will be subject to the 21 percent excise tax imposed under...more
As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more
In a presentation at McDermott’s Employment and Employee Benefits Forum, Andrew Liazos discussed areas of focus for Section 162(m) and third-party loan funding for employee stock purchase plans (ESPPs). He also provided...more
• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more
Tax-exempt organizations may be surprised to learn of the practical impact of a statute enacted as part of the Tax Cuts and Jobs Act in December 2017. Section 4960 of the Internal Revenue Code immediately put in place...more
On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (H.R. 1), or the "Act," a comprehensive tax reform package representing an overhaul of federal taxation arguably ona level not seen in more than...more
On December 22, 2017, President Trump signed into law a tax bill reconciling both the House and Senate versions of the so-called Tax Cuts and Jobs Act. The Act’s major provisions are lowering the corporate tax rate to 21%...more
On December 22, 2017, President Trump signed H.R. 1 (formerly, the “Tax Cuts and Jobs Act” (the “Act”)) into law. While the Act was primarily focused on business tax cuts and individual tax reform, the Act includes several...more
The “intermediate sanctions” rules under Section 4958 of the Internal Revenue Code have long governed the payment of compensation to executives of public charities. While these rules are highly prescriptive, if followed, they...more
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more
On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its tax reform bill titled the Tax Cuts and Jobs Act (the “House Bill”). On November 6, 2017, Kevin Brady, Chairman of the...more
On November 2, 2017, House Republicans released their highly anticipated tax reform proposal formally named the Tax Cuts and Jobs Act (the "Act"). The Act must be approved by both the House and the Senate and signed by the...more
The House GOP tax reform bill introduced Nov. 2, 2017, would have a major impact on employee benefits, including executive compensation, qualified retirement plans, fringe benefits and tax-exempt organizations. If adopted,...more