Advising pension plans and other tax-exempt entities on investments in partnerships

Article Abstract:

Tax practitioners, in advising pension plans and other tax-exempt investors, should be informed about the Tax Code's unrelated business taxable income (UBTI) laws and the Employee Retirement Income Security Act of 1974 (ERISA). This would allow tax-exempt entities to be on equal footing with the taxable companies. Pension plans under Section 501(c)(3) should know whether their investment can yield UBTI under Section 512 or unrelated debt-financed income under Section 514.

Tax Management, Analysis, Tax accounting, Pension funds, Tax exemption, Tax exemptions, Unrelated business income tax

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Proposed regulations on qualified nonrecourse financing help clarify open issues

Article Abstract:

The Proposed Regulation Section 1.465-27 issued by the Treasury Department sheds light on the ambiguities of some rules of the qualified nonrecourse financing. However, there are still some areas where guidance is necessary, among which is the consequence on the at-risk exemption for the grandfathered investment of the pre- '87 partners with the turn over of property or partnership interests into another new partnership.

Public Finance Activities, Real Estate, Real Estate and Rental and Leasing, Property Taxes, Interpretation and construction, Evaluation, Real estate industry, Property tax

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