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IRS Issues (and Seeks Comments on) Standards for Qualifying an LLC as a 501(c)(3) Entity
Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social media platforms in the 2000’...
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Today in Tax: Spin-offs, Tax Elections, and Subpart F
Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation
Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...
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Burr Takes Aim . . . This Time at Non-Taxable Scholarships
On September 29, 2021 Senator Richard Burr (R-NC) introduced legislation that would cause student-athletes to pay federal income tax on athletic scholarships if those student-athletes earn more than $20,000 in receipts from monetizing their name, ima...
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Charitable Remainder Trusts: An Option to Consider
Those wishing to sell and diversify highly appreciated assets (stocks, real estate) and those who have lots of taxable income should consider a charitable remainder trust (“CRT”) to minimize income tax on capital gains as well as gift and estate tax....
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Tips for Nonprofit Subsidiary LLCs
Nonprofit charities regularly own or receive donations of real estate. In the real estate world, holding title to property in an isolated limited liability company is so common that many lenders’ and brokers’ template forms refer to “______ LLC,” wit...
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