First 60 Days of the Trump Administration: Food and Agriculture Policy
Business Better Podcast: Manufacturing Moment - Manufacturers’ Priorities for the New Administration
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
GILTI Conscience Podcast | Gearing Up for Pillar Two
#WorkforceWednesday: SCOTUS in Review, Biden Acts to Limit Non-Competes, NY HERO Act Model Safety Plans - Employment Law This Week®
SCOTUS Watch: The ACA and Key Health Law Areas Justice Barrett Could Impact - Diagnosing Health Care Podcast
2020 Presidential Candidates' Tax Proposals
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Texas v. United States of America
Qualified Opportunity Zone Fund Investments
Investment Management Update – Exit Strategies
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Taking Advantage of Opportunity Zones: A Panel Discussion
[WEBINAR] Labor & Employment Law: What Changed in 2017
Impact of Tax Reform on Charitable Giving
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
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
Proposed Regulations published by the Treasury Department last month provide helpful clarifications regarding the application of the excise tax under Section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”)....more
Proposed Treasury regulations published earlier this month contain limited relief for tax-exempt entities. If followed carefully, those regulations can enable tax-exempt entities (and any related for-profit corporations) to...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
Just in time for the holidays, Congress gave two gifts to tax-exempt organizations as part of the new government funding bill signed into law on December 20, 2019....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
Companies that have a private foundation (or are otherwise related to a tax-exempt organization) should take immediate action to determine whether they owe an excise tax under new section 4960 of the Internal Revenue Code....more
Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more
The Tax Cuts and Jobs Act of 2017 added several new provisions to the Internal Revenue Code (the “Code”) which impose new excise taxes on tax-exempt entities. One of these new provisions is Code Section 4960, Tax on Excess...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
• 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
As part of 2017’s Tax Cuts and Jobs Act, Congress added new Section 4960 to the Internal Revenue Code. Section 4960 imposes an excise tax — currently set at 21 percent — on “applicable tax-exempt organizations” that pay...more
On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more
The Tax Cuts and Jobs Act imposes a 21 percent excise tax on charitable hospitals and other tax-exempt organizations that pay excess remuneration or excess parachute payments to certain highly-compensated employees. On...more
As we previously reported, the Tax Cuts and Jobs Act, which was signed into law at the end of 2017, imposes an excise tax on certain tax-exempt organizations equivalent to 21% of “excess compensation” (including certain...more
To start the New Year, the IRS issued 92 pages of interim guidance (Notice 2019-09) on Code Section 4960, the Tax Cuts and Jobs Act provision that imposes a 21% excise tax on remuneration in excess of $1 million and excess...more
The Tax Cuts and Jobs Act of 2017 imposes excise taxes on tax-exempt organizations who pay compensation excess of $1 million or make certain “excess parachute” payments on account of termination of employment. ...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
As is well known, on December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Final Bill”) into law. During the course of this massive legislative effort, various provisions affecting tax-exempt organizations...more
The 2017 Tax Cut and Jobs Act, signed into law on December 22, 2017, added Internal Revenue Code section 4960, which imposes a 21% excise tax on annual compensation in excess of $1 million paid by an “applicable tax-exempt...more
The 2017 Tax Cut and Jobs Act,signed into law on December 22, 2017, added Internal Revenue Code section 4960, which imposes a 21% excise tax on annual compensation in excess of $1 million paid by an “applicable tax-exempt...more
As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act (the “Act”), signed into law at the end of 2017, contains significant changes affecting the tax treatment of certain fringe benefits and executive...more
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more