...to the IRA for purposes of the unrelated business taxable income rules (UBTI) of Code Sections 511 et seq. The IRA as a shareholder may...
In his Estate Planning and Philanthropy column, Conrad Teitell, a principal at Cummings & Lockwood, writes that it isn't every day - indeed every year - that the IRS and the Treasury make pronounceme
...Code are subject to tax on their unrelated trade or business income (UBTI).1 Generally, income is UBTI if it is derived from...
...the Code) as amended, are taxable under the unrelated business taxable income (UBTI) regime of §511 et seq. of the Code when they sell...
Elliot Pisem and David E. Kahen, members of the law firm of Roberts & Holland, write that the Tax Court's recent decision in Taproot Administrative Services Inc. v. Commissioner represents, in a sens
Conrad Teitell, a principal at Cummings & Lockwood, writes that the Treasury has proposed regulations that will "confirm" that a charitable lead trust provision (or local law) that specifies the sour
Mitchell L. Berg, a partner at Paul, Weiss, Rifkind, Wharton & Garrison and Andrew J. Bates, an associate at the firm, analyze a form of financing that has increasingly been used by real estate funds
Conrad Teitell, a principal at Cummings & Lockwood, writes that, as all but troglodytes know about the background of IRA/charitable rollovers, for 2007 (and last year) an individual age 70 and one-ha
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