Topic
Charitable Contribution Deduction
256 published works
Rubin On Tax
Update: Appellate Court Upholds Denial of Charitable Deduction for Reporting Omission
Back in 2017, I discussed the case of Reri Holdings I, LLC here. There, the Tax Court denied a charitable deduction of over $33 million since the taxpayer did not…
Nonprofit Law Prof Blog
Final SALT 170 Regulations Hold the Course; Notice Provides Safe Harbor for Taxpayers With SALT Below SALT Deduction Limit
The Treasury Department and IRS just issued the final regulations under Internal Revenue Code section 170 relating to the effect of state and local tax (SALT) credits on charitable contribution…
Tax Controversy 360
Weekly IRS Roundup June 10 – 14, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10 – 14, 2019. June 11, 2019: The IRS…
21st Century Taxation
Latest Guidance on SALT Cap and Donations + Notice 2019-12 Safe Harbor
The $10,000 cap on itemized deductions of state and local taxes led a few states to add new "workarounds" such as offering a credit that would reduce state taxes (where…
Nonprofit Law Prof Blog
When Charitable Deductions are Made by Carried Interest Holders
Forbes Magazine has a short but interesting piece on how fund managers get an even bigger tax break when they use income from a carried interest to make a charitable…
Religion Clause
Tax Court Denies Deduction For Evangelist’s Expenses
In Oliveri v. Commissioner (US Tax Ct., May 28, 2019), the U.S. Tax Court rejected claims by a Catholic evangelist that the disallowance of a charitable deduction for many of his…
Nonprofit Law Prof Blog
Charitable Contribution Cases: An Alleged $151 Million Conservation Easement; Tens of Millions in Bogus Contributions
Two recent cases highlight ongoing issues with the federal charitable contribution deduction.In Battelle Glover Investments, LLC v. Commissioner (link to petition available from Tax Analysts; subscription required), a partnership is…
Nonprofit Law Prof Blog
Galle: Empirical Assessment of the Tax Exemption for Charitable Property
Brian Galle (Georgetown) has authorized a research paper entitled, "The Tax Exemption for Charitable Property: An Empirical Assessment," which he recently presented at Duke's Tax Policy Workshop Series. Here is…
Nonprofit Law Prof Blog
How Charitable Contribution SALT Workarounds work (in the absence of proposed regulations)
Darryll K. Jones
Nonprofit Law Prof Blog
Revenue Procedure 2019-12 Allows Limited Corporate and Passthrough Entity SALT Workarounds
Revenue Procedure 2019-12 provides for a seemingly unjustifiable horizontal inequity when it comes to individual state and local taxes. I could be wrong, these are just my first thoughts and…