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Income Tax Issues Arising From Endowment & Employee Plan Investments -Pass-Through Entities 4173322B
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Explore income tax issues arising from the investment of endowment and trust funds in pass-through alternative investments. Focus on unrelated business income tax (UBIT) relating to income from investments rather than operating business activities. Review debt financed income and discuss exceptions to acquisition indebtedness for qualified plans and schools.

 Export to Your Calendar 10/26/2017
When: 12:00 PM to 3:00 PM
Where: Webinar/Webcast
United States
Presenter: Richard Ruvelson, J.D.
Contact: April Deneault
801-466-10473


Online registration is available until: 10/26/2017
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Curriculums:   Not-for-Profit

NASBA Credit Category:  Taxes

CPE Hours:  3

Description

Explore income tax issues arising from the investment of endowment and trust funds in pass-through alternative investments. Focus on unrelated business income tax (UBIT) relating to income from investments rather than operating business activities. Review debt financed income and discuss exceptions to acquisition indebtedness for qualified plans and schools.

Also, discuss the state of UBIT rules. Federal and state rules differentiate between corporate and trust taxpayers with respect to tax rates and contribution deduction rules. States differ regarding the return completion of UBIT, corporate or trust and/or tax rates. Allocations of activities to states may leave investors with a federal UBIT loss and positive taxable income or loss in some states. Discuss the relevance of blocker entities and the rules for filing and completing the following forms related to foreign holdings: Form 8865; Form 926; Form 5471; Form 8621 and FinCen Report 114.

Materials are provided as an ebook for this course.



Major Subjects

  • Definition of unrelated business
  • Unrelated business taxable income modifications, exceptions and exclusions
  • “S” Corporation issues
  • Debt financed income
  • Schools and qualified plans acquisition indebtedness exception
  • Publicly traded partnerships
  • Blocker corporations
  • Investor deductions
  • Form 990-T
  • Filings relating to foreign investments Form 990 Schedule F
  • Corporations versus trusts
  • State taxation

Objectives

  • Review unrelated business income tax (UBIT)
  • Identify exclusions, modifications and exceptions to UBIT and their application to investment income
  • Discuss “S” Corporation issues
  • Identify debt financed income
  • Identify the “exception to the exception” for qualified plans and schools
  • Discuss blocker corporations
  • Recognize Form 990-T filing issues
  • Identify deductible investor expenses
  • Identify forms potentially required for foreign investing activity
  • Identify requirement for Form 990 Schedule F disclosure
  • Determine state UBIT filing requirements

Level:  Intermediate

Designed For

CPAs working with exempt organizations and professionals who are responsible for filing Form 990-T or are responsible for consulting on the taxation of investments and/or new revenue generating endeavors.

Advanced Prep:

None.

Prerequisite

Knowledge or experience in preparing or reviewing Form 990-T, or experience as controller, analyst, CFO or investment manager.

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