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Tax Exempt Entities Loans

Rivkin Radler LLP

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

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Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more

Proskauer Rose LLP

Understanding the Increasing Use of Holdco NAV Loan Structures

Proskauer Rose LLP on

While the market for NAV financings—loans to funds supported by the net asset value of their portfolios—grew in 2023 and continues to rapidly evolve, a consensus has developed around what is sometimes referred to as a “Holdco...more

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Polsinelli

IRS Ruling Takes Aim at Impact Investing

Polsinelli on

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more

McDermott Will & Schulte

Changes in Executive Compensation

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

Morgan Lewis

IRS Delays Effective Date for New Regulations on Embedded Loans in Swaps

Morgan Lewis on

The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more

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