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Searching Content indexed under Tax Authorities by Amanda Nussbaum ordered by Published Date Descending.
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1
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
2
Section 1446(f) Proposed Regulations: Key Guidance On Partnership Interest Transfers By Non-U.S. Persons
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
United States
6 Jun 2019
3
Parsonage Exclusion Found By Seventh Circuit To Be Constitutional
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
United States
17 Apr 2019
4
Five Excise Tax Tips For Tax-Exempt Employers
As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect many tax-exempt employers.
United States
21 Mar 2019
5
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
6
IRS Releases Interim Guidance On New Excise Tax On Executive Compensation Paid By Tax-Exempt Organizations
On December 31, 2018, the Department of the Treasury ("Treasury") and the Internal Revenue Service (the "IRS") released Notice 2019-09 (the "Notice"),
United States
18 Jan 2019
7
Tax Reform: UBTI Guidance On Qualified Transportation Fringe Benefits
From Proskauer's Not For Profit / Exempt Organization Blog, a discussion of recent IRS guidance and New York State legislative relief on Internal Revenue Code 512(a)(7)
United States
28 Dec 2018
8
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 ...
United States
28 Dec 2018
9
FATCA: Significant Relief In New Proposed Regulations
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
United States
21 Dec 2018
10
Proskauer's 23rd Annual Trick Or Treat Seminar
Amanda Nussbaum welcomed everyone and briefly discussed the five major trends impacting tax-exempt organizations today, including the general impact of the Tax Cuts and Jobs Act (the "Act")...
United States
13 Nov 2018
11
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
12
Tax-Exempts May Limit Fund Investments Pursuant To New IRS Guidance On UBTI
On August 21, 2018, the Internal Revenue Service ("IRS") released Notice 2018-67 (the "Notice"), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6)
United States
5 Sep 2018
13
Treasury And IRS Issue Proposed "Pass-Through Deduction" Regulations
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction"
United States
31 Aug 2018
14
New Tax Law (H.R. 1): Key Highlights Related To Interest Bearing Debt
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
United States
15 Jan 2018
15
U.S. Tax Reform – Key Highlights For Private Investment Funds In Tax Cuts And Jobs Act Bill
On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill").
United States
19 Dec 2017
16
Updates For Tax-Exempt Organizations From The Senate Bill
Early on December 2, 2017, the Senate passed the Tax Cuts and Jobs Act (the "Senate Bill").
United States
7 Dec 2017
17
Tax Reform: Focus On The Sports Industry
The Senate Markup proposes to eliminate the tax exemption for professional sports leagues, regardless of size.
United States
14 Nov 2017
18
IRS Updates FATCA FAQs, Addresses January Temporary Regulations
Question 21 provides temporary relief from the new requirement of providing a foreign TIN for calendar year 2017 in the absence of the withholding agent's actual knowledge that the beneficial owner...
United States
26 Apr 2017
19
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
20
IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385
On October 13, 2016, the Treasury Department and the Internal Revenue Service (IRS) issued final and temporary regulations under section 385 of the Internal Revenue Code.
United States
27 Oct 2016
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