News & Analysis as of

Internal Revenue Code (IRC) Income Taxes Tax Exemptions

Morrison & Foerster LLP

One Big Beautiful Bill Expands Qualified Small Business Stock Exemptions

President Trump signed into law the One Big Beautiful Bill Act (the “Act”) on July 4, 2025 (the “Signing Date”). Among the Act’s significant tax extensions and changes to tax law are several taxpayer-favorable revisions to...more

Schwabe, Williamson & Wyatt PC

U.S. Treasury Announces Tribal Consultation on General Welfare Exclusion Act

On June 30, 2025, the United States Department of the Treasury announced that it will be holding an online tribal consultation with Alaska Native Corporations on July 29, 2025, from 1:30 pm to 4:30 pm ET, to discuss the...more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

Chambliss, Bahner & Stophel, P.C.

Tax Break Helps Pay for CCRC Fees

A lesser-known financial upside of Continuing Care Retirement Community (CCRCs) is the potential tax deductibility of a portion of the entrance fee and monthly fees....more

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

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

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Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

Freeman Law

Colorado Religious Property Tax Exemption and UBI

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Property owned by qualified religious organizations in Colorado may enjoy an exemption from state property tax. To enjoy exemption, the real and personal property must be owned and used “solely and exclusively for religious...more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Foodman CPAs & Advisors

Tax Preparation 2025 Useful Pointers

On 12/19/24, anticipating the 2025 filing season, the IRS published Tax Preparation 2025 Useful Pointers in IR-2024-311: Prepare to file in 2025: Get Ready for tax season with key updates, essential tips. As the 2025 filing...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

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The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Foley & Lardner LLP

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

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On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more

Farella Braun + Martel LLP

Nonprofit Basics: Unrelated Business Income Tax: Basic Rules for Charities - Part 1

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and episode 107 is the first in a series of technical episodes describing the basic principles of the tax on unrelated business income generated...more

McDermott Will & Emery

IRS Roundup for November 25 – December 13, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2024 – December 13, 2024....more

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

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more

Falcon Rappaport & Berkman LLP

For Tax Purposes, Are Limited Partners Really Limited Partners?

In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

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In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Rivkin Radler LLP

Nothing Lasts Forever –Expiring Tax Provisions

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The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more

Kohrman Jackson & Krantz LLP

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more

Rivkin Radler LLP

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

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It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

McDermott Will & Emery

Weekly IRS Roundup July 24 – July 28, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023. July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30,...more

Ballard Spahr LLP

IRS Addresses Non-Exempt Tax Status for NIL Organizations

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Summary - The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more

McDermott Will & Emery

Weekly IRS Roundup May 8 – May 12, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 – May 12, 2023...more

Freeman Law

Tax Court in Brief | Commonwealth Underwriting & Annuity Servs. v. Comm’r | Denial of Exemption Under IRC 501(c)(15)

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Summary: Commonwealth challenges the IRS’s denial of application for tax exemption under 501(a), claiming, by submission for declaratory judgment, to be an organization described in section 501(c)(15). Commonwealth was...more

Freeman Law

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

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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

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