LexisNexis® Legal Newsroom
Recent TAM on a Sport Association’s UBTI Finds Acceptable Split of Income and Employee Activity

One issue that perpetually plagues a tax-exempt organization is whether the income it receives from its unrelated trades or businesses (its "unrelated business taxable income" or UBTI) is so large that it will cause it to lose its tax-exempt status. This issue is difficult because there...

When California's Tax Conformity Act of 2010 Does Not Conform: California Does Not Follow the Federal Fix for CRTs with UBTI

California recently passed a bill to conform its tax law with the federal income tax law, but specifically did not accept the Federal fix for unrelated business taxable income (UBTI) of charitable remainder trusts (CRTs). Therefore, if a CRT in California has UBTI it will be subject to California income...

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses that rob the U.S. Treasury."[1] Although most...

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses that rob the U.S. Treasury."[1] Although...