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#WorkforceWednesday: SCOTUS in Review, Biden Acts to Limit Non-Competes, NY HERO Act Model Safety Plans - Employment Law This Week®
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2020 Presidential Candidates' Tax Proposals
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Qualified Opportunity Zone Fund Investments
Investment Management Update – Exit Strategies
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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
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more
President Trump has indicated that one of his key economic priorities is to extend the expiring provisions of the Tax Cuts and Jobs Act (TCJA). However, Congress still needs to resolve disagreements on the cost and funding of...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
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
The Taxpayer Certainty and Disaster Tax Relief Act of 2019 (the “Relief Act”) has retroactively repealed a provision known as the “parking lot tax.” ...more
The IRS is revising Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions, to help charities apply for 501(c)(3) tax-exempt status. Effective January...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
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
On December 10, 2018, the IRS issued Notice 2018-99 (the "Notice") which is designed to serve as interim guidance on determining unrelated business taxable income ("UBTI") related to nondeductible qualified parking offered by...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
The Internal Revenue Service issued guidance last December to help employers that own or lease employer parking facilities or reimburse employees for parking expenses to navigate the recent change to the parking expense...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
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
The Treasury Department recently published guidance on determining the amount of qualified transportation fringe benefit expenses that are nondeductible and, for tax-exempt organizations, the amount that should be treated as...more
December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the “Code”), which requires tax-exempt employers to increase their unrelated business taxable income (“UBTI”) by...more
The Internal Revenue Service recently issued Notice 2018-99 to address changes in the Internal Revenue Code included in the Tax Cuts and Jobs Act (TCJA). ...more
Under the Tax Cuts and Jobs Act (TCJA, December 22, 2017), tax-exempt investors must now calculate unrelated business taxable income (UBTI) separately with respect to each trade or business. As a result, a deduction from one...more
In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more
On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...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