By NEO Law Group
In Part I of this two-part article on IRS Notice 2018-67 regarding the calculation of unrelated business taxable income (UBTI) under the Tax Cuts and Jobs Act (TCJA), we discussed the need to separate different lines of unrelated business activities, which is now required to calculate an organization’s unrelated business income tax (UBIT)....
On August 21, 2018, the IRS released Notice 2018-67 which both provides preliminary guidance and seeks comments on the calculation of unrelated business taxable income (UBTI) under the Tax Cuts and Jobs Act (TCJA). Tax-exempt organization that may be earning unrelated business income should be aware of the changes...
Thanks to the Tax Cuts and Jobs Act (TCJA), if your nonprofit provides parking to its employees, it may now need to pay unrelated business income tax (UBIT) on the value of that parking benefit. That’s right – your tax-exempt organization may now need to pay income tax on an...
Is it possible for a 501(c)(3) organization to change into a 501(c)(4) organization? The short answer is no (Revenue Procedure 2017-5). But it may be possible for a 501(c)(3) organization to cause the creation of a 501(c)(4) organization and subsequently dissolve, leaving only the 501(c)(4) organization. This strategy has...
The Treasury Department announced a change in the regulations making it no longer necessary for 501(c)(4) and 501(c)(6) organizations to disclose the identities of their donors on their annual information returns to the IRS. More specifically, tax-exempt organizations described by section 501(c), other than section 501(c)(3) organizations, are no...
I’ll be joining CalNonprofits CEO Jan Masaoka for a webinar on Thursday, June 28th from 11am to 12pm (Pacific). We’ll be discussing the major ongoing filing obligations that California nonprofits that are exempt under IRC Section 501(c)(3) are subject to each year. Join us for an engaging webinar on...
Thanks to our friends at Perlman+Perlman for providing us with permission to re-publish this important post on private benefit issues raised by nonprofit/for-profit tandem structures by one of its partners, Allen Bromberger, whose bio we include at the end of the post. One of the basic principles of tax-exempt...
In connection with the release of the IRS Tax Exempt and Government Entities FY 2018 Work Plan (which we wrote about here), the IRS promised to release the complete FY 2017 (Oct. 1, 2016, to Sept. 30, 2017) accomplishments when final results became available. The Tax Exempt and Government Entities FY...
Erin and I just returned from Georgetown Law School’s Nonprofit Governance and Representing and Managing Tax-Exempt Organizations conferences. We had a great time learning and meeting with some of the brightest and most respected professionals across the country, including several friends. I also had the honor of speaking on a panel...
In a previous post (“Affiliated Organizations: Sharing Employees“), we examined how an affiliated 501(c)(3) organization and 501(c)(4) social welfare organization (or 501(c)(6) business league) can “share” employees. Such affiliations provide an ability to coordinate activities and share resources to more effectively and efficiently further a common goal. But, as...