REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Public Finance
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Nonprofit Basics: Unrelated Business Income Tax: Debt Financed Income - Part 3
Nonprofit Basics: Unrelated Business Income Tax: Basic Rules for Charities - Part 1
Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut
EV Tech Series: The Inflation Reduction Act’s Impact on the Energy Industry With Judy Kwok and Marc Machlin - Battery + Storage Podcast
Tribal Tax Exemption Under McGirt Gains Preliminary Victory
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
ATTENTION ALL CADETS!
One Note Samba
Podcast: State Taxation of Digital Health Products
Investment Management Roundtable Discussion – Personal Estate Planning
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Episode 26: Talking Tax Reform and Executive Comp
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more
In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more
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
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
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
Last week, the United States General Services Administration, Department of Education, and Department of Health and Human Services sent a letter to Alan M. Garber, the President of Harvard University, and Penny Pritzker, Lead...more
Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more
Like any for-profit company, nonprofit organizations want to attract and retain high caliber executives to achieve and further their missions. To accomplish this, a nonprofit organization may have to offer a particularly...more
In the first week of March 2025, two separate Texas tax cases were filed in Texas state district court. Each of these involves, among other claims, whether taxable security services should be rendered exempt when preempted...more
As we approach the end of the first quarter of 2025, estate planners and their clients are closely monitoring developments in Washington, D.C. The scheduled sunset of the increased estate and gift tax exemption is now less...more
In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more
On 12/19/24, anticipating the 2025 filing season, the IRS published Tax Preparation 2025 Useful Pointers in IR-2024-311: Prepare to file in 2025: Get Ready for tax season with key updates, essential tips. As the 2025 filing...more
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more
The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more
Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more
On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more
Section 6417 of the Internal Revenue Code was added by the Inflation Reduction Act of 2022 (IRA). The section provides that eligible taxpayers may make an election to claim certain clean energy credits even though they have...more
In September, Treasury announced forthcoming guidance that will clarify whether the limited partner exception applies to limited partners that actively participate in their businesses....more
On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more
Summary: Commonwealth challenges the IRS’s denial of application for tax exemption under 501(a), claiming, by submission for declaratory judgment, to be an organization described in section 501(c)(15). Commonwealth was...more
Sales tax . . . A (if not the most) commonly overlooked tax for nonprofit organizations. This Freeman Law Insights blog focuses on sales tax regime applicable to “admissions” collected by or for nonprofit organizations in...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more