Alston & Bird Tax Blog

Federal Tax Advisory

Don’t Forget Ruling Guidelines

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Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant issue”Don’t assume there isn’t an IRS ruling guideline Read the full advisory here. [...]Read more

Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

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Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums. Split-dollar life insurance loans became even more beneficial after the TCJA added a new excise tax on exempt organizations under Section 4960Imputed income from below-market split-dollar life insurance loans must be included in Section 4960 calculationImputed income can be avoided by charging interest at the historically low applicable federal rate Read the full advisory here. To learn more about our exempt organization [...]Read more

Federal Tax Advisory: Disaster Losses

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With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019. An introduction to Section 165(i)The expansion of Section 165(i)Expect guidance from Treasury Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal implications of the coronavirus (COVID-19). [...]Read more