Statute
Internal Revenue Code
1,299 published works
Larry's Tax Law
A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What Happens to a Shareholder’s Return When There Is an Error on the S Corporation Return?
By Larry Brant
Basic Rules IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable…
Nonprofit Law Prof Blog
Ninth Circuit Rejects DOE’s Analysis of Grand Canyon University’s Tax-Exempt Status
It’s a shame the semester is almost over, because that means it’s too late for me to assign the Ninth Circuit’s recent opinion in Grand Canyon University v. the Department…
Global Policy Watch
501(c)(4) Organizations Could Face Additional Scrutiny Following Court Decision
By Susan Leahy, Pooja Shah Kothari
November 1, 2024, Covington Alert In a unanimous decision, the U.S. Court of Appeals for the Fifth Circuit affirmed the Tax Court’s denial of tax-exempt status for Memorial Hermann Accountable Care…
Israel Global Gateway
Navigating clean energy tax credits in climate tech venture lending
By Yael Bailey
Changes to the tax code have made it easier to monetize renewable energy tax credits, attracting interest from emerging growth companies looking to bolster their balance sheets amid the slowdown…
Nonprofit Law Prof Blog
Fifth Circuit Cites Loper Bright to Invalidate Social Welfare Reg; Declares Accountable Care Organization Ineligible for (c)(4) Status
The Fifth Circuit Court of Appeals denied social welfare status to an Accountable Care Organization on Monday. In a quiet but remarkable reversal of at least 40 years of administrative…
Nonprofit Law Prof Blog
IRS Applies Kurtz Factors to Revoke Church Tax Exemption
From Got QuestionsIn PLR 202442006, released last week, the Service applied the familiar but questionable 14-factor test to revoke a worship corporation's "church" tax exemption. This case is an easy…
Best Methods
Repatriate Intangible Property to the U.S. and Turn Off Section 367(d) Inclusions
By Jenny A. Austin, Zachary Weit
On Wednesday, October 9, 2024, the Treasury Department and the Internal Revenue Service (“IRS”) released final regulations (TD 9994), confirming that the application of section 367(d) to intangible property (“IP”)—e.g.,…
Nonprofit Law Prof Blog
BYU Determines Project 2025 is Prohibited Campaign Intervention
The Smoot Administration Building at BYUBrigham Young University has a surprisingly detailed Political Neutrality policy. Here is an excerpt describing its purpose:The essential functions of the university require strict institutional…
Cohen & Buckmann Insights
The ABCs of RMDs: A Guide to Required Minimum Distributions
Everyone has heard about required minimum distributions (RMDs) for retirement plans and IRAs, but few of us really know how they work. RMDs are the government's way of limiting tax…
Employment Law Business Guide
IRS Releases Guidance on Disaster Relief Under Qualified Plans and IRAs
The IRS recently issued a new fact sheet to answer certain FAQs about the rules in SECURE 2.0 Act of 2022 (the “Act”) that give special rights under certain qualified…