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Internal Revenue Code (IRC) Tax Exemptions

ArentFox Schiff

QSBS Gets Supercharged Under New Tax Law

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The qualified small business stock (QSBS) rules can be a powerful tax planning tool, and, following the recent enactment of a signature tax law, they have become even more potent....more

Ward and Smith, P.A.

One Big Beautiful Bill: How are North Carolina Tax-Exempt Organizations Affected?

Ward and Smith, P.A. on

There are a host of wide-ranging changes coming to the Internal Revenue Code ("Code") under the Act, including changes that affect tax-exempt organizations. North Carolina tax-exempt organizations should be aware of these...more

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...more

Foster Swift Collins & Smith

Determining Private Foundation or Public Charity Status under the Support Test

A hypothetical state law for-profit company, which may be a bank, credit union, insurance company, healthcare organization, or other entity (“Company”) intends to establish a charitable organization (“Foundation”) to carry...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more

Jones Day

Qualified Small Business Stock Benefits Expanded in New Tax Bill

Jones Day on

The One Big Beautiful Bill Act expands the qualified small business stock benefits available to founders and investors....more

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

McDermott Will & Emery

IRS roundup: June 18 – July 11, 2025

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions - On July 4, 2025, US President Donald...more

Husch Blackwell LLP

Estate Planning and Other Tax Strategies under the One Big Beautiful Bill Act

Husch Blackwell LLP on

President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law on July 4, 2025. The OBBBA represents a significant overhaul of the U.S. tax system, making permanent many provisions of the 2017 Tax Cuts and Jobs...more

Frost Brown Todd

One Big Beautiful Bill Act Enacts a Permanent Increase in the Estate and Gift Tax Lifetime Exclusion Amount for 2025 and Later...

Frost Brown Todd on

On July 3, 2025, and by a vote of 218 to 214, the U.S. House of Representative passed the Senate’s amended version of H.R. 1 (also known as the “One Big Beautiful Bill Act” or OBBBA 2025), which is the tax-and-budget...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

Patterson Belknap Webb & Tyler LLP

Changes to QSBS Rules

As if QSBS wasn’t good enough already, the “Big Beautiful Bill” signed into law by President Trump on July 4, 2025 enacts significant, founder-friendly changes to Section 1202 of the Internal Revenue Code, which substantially...more

Wilson Sonsini Goodrich & Rosati

Understanding Section 1202: The Qualified Small Business Stock Exemption

The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100 percent of the U.S. federal...more

Holland & Knight LLP

The High Stakes of Section 501(c)(3) Tax-Exempt Status Revocation: Declaratory Judgment Actions

Holland & Knight LLP on

Discussions of the tax-exempt status of universities, nonprofit advocacy groups and other Section 501(c)(3) organizations frequently have been in the news lately. The IRS revocation of a Section 501(c)(3) organization's...more

Cooley LLP

Senate Tax Bill Expands QSBS Benefits

Cooley LLP on

On June 16, 2025, the Senate Finance Committee (SFC) released a revised version of the “One Big Beautiful Bill Act” (SFC bill), following the House’s passage of the bill on May 22. The SFC bill would significantly expand the...more

Freeman Law

Housing Allowance – What is a “Minister of the Gospel”?

Freeman Law on

This Freeman Law Insights blog dives into what is a minister of the gospel for housing allowance and federal income tax purposes. Housing Allowances, Generally. Compensation for services rendered is generally...more

Cooley LLP

Trump’s Initiative to Revoke Harvard’s Tax-Exempt Status: Implications for Higher Education

Cooley LLP on

President Donald Trump has repeatedly threatened to strip the tax-exempt status from colleges and universities. Most recently, on May 2, Trump announced in a social media post, “We are going to be taking away Harvard’s Tax...more

Steptoe & Johnson PLLC

Can the IRS Revoke a University's Tax-Exempt Status Overnight?

Steptoe & Johnson PLLC on

As a result of President Trump’s recent social media posts regarding Harvard University’s tax-exempt status, some institutions of higher education (IHE) have expressed concerns over whether the Internal Revenue Service (IRS)...more

Frost Brown Todd

TEFRA Approvals: Considerations for Officeholders When Approving Private Activity Bonds

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New officeholders often ask us to clarify their responsibilities when it comes to public approval of bonds and the consequences for states and their political subdivisions when they approve bonds as tax-exempt. What follows...more

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Davis Wright Tremaine LLP

House GOP Tax Proposal Targets Nonprofits

On May 12, 2025, the House Ways and Means Committee released a draft version of the Republican-led tax bill, "The One, Big, Beautiful Bill" (the "Bill"), which is designed to advance President Trump's tax reform agenda. The...more

Partridge Snow & Hahn LLP

Tax-Exempt Financing for 501(c)(3) Borrowers – Part I: Eligibility and Issuance

When borrowing for capital projects, 501(c)(3) borrowers often have various options to achieve their financing goals. Traditional financing through a bank or engaging in specific capital campaign fundraising efforts are...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

King & Spalding

Ways and Means Committee Seeks Information Regarding OPO Activities

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On April 16, 2025, the Committee on Ways and Means in the U.S. House of Representatives issued a letter to the public requesting information regarding Organ Procurement Organizations (OPOs)—the nonprofit, tax-exempt entities...more

Winstead PC

The QPAM Exemption - Key Takeaways for Fund Managers with Benefit Plan Investors

Winstead PC on

As an asset manager, you may be familiar with the regulatory issues that come into play when a fund permits investments from “benefit plan investors,” which generally include certain employee benefit plans subject to the...more

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