The IRS has issued proposed regulations addressing the calculation of unrelated business taxable income (UBTI) for purposes of Section 512(a)(6) of the Internal Revenue Code. The proposed regulations contain needed guidance on UBTI provisions enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA).
Generally, tax-exempt organizations are subject to tax on gross income if the activity that generates the income (i) constitutes a trade or business, (ii) is regularly carried on by the organization, and (iii) the conduct of the activity is not substantially related to the performance of the organization's exempt function (other than the production of funds). Modifications to UBTI exempt certain kinds of passive income such as dividends, interest, and rents from UBTI.
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New Treasury Regulations Address Income Aggregation Rules for Tax-Exempt Organizations | Kramer
On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) addressing the manner in which tax-exempt organizations calculate their unrelated business taxable income (UBTI). The proposed regulations should reduce the administrative complexity associated with such calculations and allow tax-exempt organizations to aggregate certain income streams and corresponding deductions.
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Section 512(a)(6) was enacted into law through the 2017 Tax Cuts and Jobs Act (TCJA) and has the effect of creating separate tranches, or “silos,” of UBTI for purposes of calculating a tax-exempt organization’s tax liability. Prior to this change under the TCJA, UBTI was computed by reducing the gross income of all unrelated trades or businesses by the allowed deductions from all unrelated trades or businesses.
Illinois Counties Consider Property Tax Delays - KE Andrews
Several Illinois counties are offering economic relief to property owners affected by the state's stay-at-home order. According to the Illinois property tax code (35 ILCS 200/21-40), county governments in designated disaster areas may pass ordinances or regulations to temporarily modify the tax collections aid in recovery efforts. These modifications may include extending due dates, waiving penalties, and suspending interest.
DuPage County has suspended interest and late fees for 90 days (September 1) for residents who demonstrate financial hardship resulting directly from COVID-19.
Anti-Injunction Act Confusion Set for Resolution by High Court (1)
The outcome of a case now before the U.S. Supreme Court may lessen the uncertainty caused by past court decisions over the scope of legal protections for tax regulatory actions.
The case concerns the Anti-Injunction Act, a Civil War-era statute that generally bars lawsuits trying to restrain tax assessment or collection. Courts have often interpreted the act to block challenges to tax regulatory actions that haven't yet been enforced against a taxpayer. That interpretation distinguishes court treatment of Treasury Department regulatory actions from those of other federal agencies, which typically face such lawsuits.
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IRS Allows Telephonic TEFRA Hearings in Light of COVID-19 | Bracewell LLP - JDSupra
As a result of the prohibitions on public gatherings resulting from the COVID-19 pandemic, issuers of tax-exempt private activity bonds have been facing difficulty complying with the federal tax laws requiring that a public hearing be held to allow interested individuals to express their views on the bonds and the related project (commonly referred to as “TEFRA hearings”).
Recognizing this problem, the IRS has provided temporary relief in Revenue Procedure 2020-21 (“Rev. Proc. 2020-21”), which allows issuers to hold telephonic TEFRA hearings that are accessible to the residents of the approving governmental unit by calling a toll-free telephone number. Provided a toll-free telephone number is available, issuers may also offer additional access to the TEFRA hearing by other telephone numbers or by internet-based meeting technology.
Globally (Not So) Mobile Employees: Taxation of Equity Awards in a COVID-19 World | McDermott
The rules relating to the US taxation of equity awards in an international context are often complex and sometimes uncertain. This On the Subject explores how COVID-19-related travel restrictions affect the US taxation of certain equity awards for employees transferred to and from US-based employers.
The US tax rules governing the taxation of equity awards for globally mobile employees are complex and in some cases, uncertain. Among other things, employers must consider the type of award, grant and vesting dates, and sourcing rules to ensure proper reporting and withholding for non-US employees that have worked in the United States.
Bunge Reports First Quarter 2020 Results | News | webstercountycitizen.com
ST. LOUIS , May 6, 2020 /PRNewswire/ -- Bunge Limited (NYSE: BG) today reported first quarter 2020 results.
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Greg Heckman , Bunge's Chief Executive Officer, commented, "I am incredibly proud and grateful for our team's commitment and performance during this highly challenging period. Bunge is a critical part of the global food infrastructure, and our team remains dedicated to ensuring that key feed and food ingredients are getting from farmers to consumers as we navigate this global crisis together.
Financial Focus: Working from Home? Can You Write Off Expenses On Your Taxes? - Norwood News
Has your employer paid you for those extra expenses? If not, can you write these items off on your taxes? The answer is yes, but first a little history! Prior to 2017, working-from-home costs were deductible as a personal exemption under “job and miscellaneous” expenses on your tax return.
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While these working-from-home costs were not fully deductible up to 2017, it’s safe to say that most Americans probably recouped 25 percent of their monies under this former tax regime.
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