News & Analysis as of

U.S. Treasury Tax Exemptions

Cadwalader, Wickersham & Taft LLP

House Republicans to Large Endowments: “Ask Not What …”

Under the House’s current draft budget bill, which was released on May 15, 2025, the 1.4% excise tax on private universities’ net investment income would increase up to 21%, effectively negating one of the main benefits of...more

Ropes & Gray LLP

House Passes Tax Package with Several Carved-Back Provisions Relevant to Tax-Exempt Organizations

Ropes & Gray LLP on

On May 22, 2025 the House of Representatives passed its version of the “One Big Beautiful Bill Act” (the “BBB”). As described in our prior Alert, the proposed package includes several key provisions of particular importance...more

Bricker Graydon LLP

The Possible Repeal of the Tax Exemption of Municipal Bond Interest

Bricker Graydon LLP on

You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.”  This issue...more

Holland & Knight LLP

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

Bracewell LLP

Treasury and IRS Issue Final and Proposed Regulations Expanding Applicable Entities’ Ability to Elect Direct Pay in Connection...

Bracewell LLP on

On November 19, 2024, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 761 (the Final Regulations) enabling certain entities to make a direct pay...more

Proskauer Rose LLP

Personal Planning Strategies - November 2024

Proskauer Rose LLP on

What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer Relief Act of 2012 (the "2012 Act"). In...more

Seyfarth Shaw LLP

Demystifying the Corporate Transparency Act for Tax-Exempt Organizations – Part 2: CTA Compliance for Subsidiaries of Tax-Exempt...

Seyfarth Shaw LLP on

This article provides Corporate Transparency Act (CTA) guidance to tax-exempt organizations with subsidiaries. For a general overview of CTA compliance for nonprofit and tax-exempt organizations, please see Part 1: When to...more

Seyfarth Shaw LLP

Demystifying the Corporate Transparency Act for Tax-Exempt Organizations – Part 1: When to File a Beneficial Ownership Information...

Seyfarth Shaw LLP on

The Corporate Transparency Act (CTA) took effect on January 1, 2024 and some U.S. nonprofits and tax-exempt organizations are still debating how the CTA applies to them. This article provides newly-formed and existing...more

Cadwalader, Wickersham & Taft LLP

Guidance on Limited Partnership Exception May Include a Functional Analysis Test

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

Rivkin Radler LLP

Not-for-Profits and the CTA

Rivkin Radler LLP on

Recently, there has been extensive reporting about the federal Corporate Transparency Act, or the “CTA,” the stated objective of which is to enhance transparency in entity structure and ownership in order to combat money...more

Fox Rothschild LLP

The Corporate Transparency Act’s Effects on Nonprofits

Fox Rothschild LLP on

The Corporate Transparency Act (CTA), a new federal financial reporting law that will take effect on Jan. 1, 2024, is a hot topic in the corporate world these days. However, nonprofits also need to be aware of the law, which...more

Vinson & Elkins LLP

Full Speed Ahead: The Inflation Reduction Act at One Year

Vinson & Elkins LLP on

It’s the largest climate legislation in US history, with many complex provisions. But let’s start with the big picture: A year on from the Inflation Reduction Act becoming law, is it living up to its promise?...more

Paul Hastings LLP

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

Holland & Hart LLP

Top 10 Things to Know: Proposed Regs for Renewable Energy Direct Pay & Direct Transfer

Holland & Hart LLP on

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

Foley & Lardner LLP

Qualifying Qualified Broadband Projects: NABL’s Request for Guidance to Clarify Qualified Broadband Project Provisions

Foley & Lardner LLP on

The Infrastructure Investment and Jobs Act (“IIJA”) has provisions to encourage investment in high-speed broadband projects, but as written, the legislation leaves open for interpretation several provisions. Guidance or...more

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

Paul Hastings LLP on

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

Bracewell LLP

Certain CCUS Projects Now Eligible for Financing with Tax-Exempt Bonds

Bracewell LLP on

Tax-exempt bonds can now be added to the list of ways in which carbon capture, utilization and storage (“CCUS”) projects can be financed. Specifically, the Infrastructure Investment and Jobs Act (the “Act”) amends section...more

Verrill

Using a Non-Compete to Create a Substantial Risk of Forfeiture Under a Section 457(f) Plan: Limited (But Meaningful) Opportunities

Verrill on

The Treasury Department’s proposed regulations regarding the income tax treatment of “ineligible plans” of tax-exempt employers under Code Section 457(f), published in June 2016, were greeted with much fanfare. (You can...more

McDermott Will & Emery

Weekly IRS Roundup October 18 – October 22, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 18, 2021 – October 22, 2021... October 18, 2021: The IRS announced that beginning...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on

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

Snell & Wilmer

Final Treasury Regulations Reduce Donor Reporting Requirements for Some Tax-Exempt Organizations

Snell & Wilmer on

The Department of the Treasury has adopted Final Regulation, providing guidance on information to be reported on the annual return of tax-exempt organizations with respect to their “substantial contributors." For these...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

No Taxation With Religious Invocation: Seventh Circuit’s Decision to Impact Ministerial Employees

In Gaylor v. Mnuchin, the Seventh Circuit Court of Appeals recently held that a tax code exemption for religious housing of ministers does not violate the Establishment Clause of the First Amendment of the U.S. Constitution....more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Proskauer Rose LLP

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Hogan Lovells

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

40 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide