News & Analysis as of

Tax Exempt Entities UBTI Internal Revenue Code (IRC)

Freeman Law

What is an Integrated Auxiliary of a Church?

Freeman Law on

Under Section 508 of the Internal Revenue Code, churches, their integrated auxiliaries, and conventions or associations of churches are not required to apply for recognition as a tax-exempt organization under Section...more

Dickinson Wright

Exempt Organizations May Claim a Refund for Amounts Paid Under the TCJA's "Parking Lot Tax"

Dickinson Wright on

The Taxpayer Certainty and Disaster Tax Relief Act of 2019 (the “Relief Act”) has retroactively repealed a provision known as the “parking lot tax.”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

Harris Beach Murtha PLLC

IRS Provides Guidance on Calculation of Unrelated Business Taxable Income for Nondeductible Employee Parking Expenses

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

Williams Mullen

New Parking Expense Rules for Taxable Employers and Tax-Exempt Organizations

Williams Mullen on

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

Blank Rome LLP

Treasury Department Issues Guidance on Tax Treatment of Qualified Transportation Fringe Benefits

Blank Rome LLP on

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

Proskauer - Not for Profit/Exempt...

Inclusion of Qualified Transportation Fringe Benefits in UBTI: Guidance, Relief, and Rumors of Possible Repeal

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

A&O Shearman

IRS Issues Guidance Affecting Tax-Exempt Investments in Private Equity Funds

A&O Shearman on

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

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

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

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

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

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

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