Treasury Issues Proposed UBIT Regs (April 24, 2020)

Treasury has issued proposed regulations that clarify a provision in the 2017 tax law that requires nonprofit organizations to calculate unrelated business income tax ("UBIT") separately for each trade or business. The summary for the proposed regs is as follows: This document contains proposed regulations that provide guidance on how an exempt organization subject to … Continue reading Treasury Issues Proposed UBIT Regs (April 24, 2020)

Tax Policy Center Conference: Taxes and the Future of Philanthropy (Feb. 18, 2020)

The Urban-Brookings Tax Policy Center and the American Tax Policy Institute held a joint conference on February 18, 2020 on Taxes and the Future of Philanthropy. The summary of the conference is as follows: The philanthropic sector currently faces a difficult challenge: Recent changes to the tax law leave only about 10 percent of households, … Continue reading Tax Policy Center Conference: Taxes and the Future of Philanthropy (Feb. 18, 2020)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020)

Bryan Camp has published an article on the Tax Prof Blog, entitled Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020).  The article begins as follows: Tax statutes and tax regulations mostly use words to talk about numbers.  One of the basic lessons I must teach students is how … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020)

Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020): LLC Not Entitled to Charitable Conservation Deduction for Conservation Easement

In Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020) the Tax Court held that an LLC was not entitled to a charitable contribution deduction for a conservation easement. The taxpayer executed a deed declaring a conservation easement in favor of a tax-exempt charitable organization. The deed provided that, if the easement was … Continue reading Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020): LLC Not Entitled to Charitable Conservation Deduction for Conservation Easement

Carter v. Commissioner, T.C. Memo 2020-21: Married Individuals Denied Charitable Contribution Deductions; Supervisory Approval Not Met

In Carter v. Commissioner, the Tax Court upheld the disallowance of charitable contribution deductions for the conveyance of an easement to a qualified organization. The opinion synopsis is as follows: DH, a partnership of which Ps were partners, conveyed to NALT, a "qualified organization" within the meaning of I.R.C. sec. 170(h)(3), an easement that restricts … Continue reading Carter v. Commissioner, T.C. Memo 2020-21: Married Individuals Denied Charitable Contribution Deductions; Supervisory Approval Not Met

Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically

The IRS has released guidance in Rev. Proc 2020-8 that requires electronic submissions of Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code. The guidance provides a 90-day transition relief period, during which paper Form 1023 applications will be accepted. This revenue procedure also modifies language related to the … Continue reading Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically