The Inflation Reduction Act (IRA) is considered among the most ambitious pieces of climate legislation in US history. Extending or introducing lucrative tax credits for a variety of clean tech manufacturing and deployment facilities -- including wind, solar, hydrogen, and nuclear -- and introducing new methods to monetize these credits, the IRA has changed the landscape for incentivizing industrial-scale decarbonization activities in the United States. Don’t miss out on this opportunity to learn the background, guidance, and opportunities presented by these tax incentives in the commercial energy infrastructure and manufacturing space.

With approximately half of the global population participating in national elections in 2024 and U.S. campaigns pivoting from the primaries to start their national election campaigning, politics are front and center. And tax-exempt public charities and foundations care deeply about many of the issues that will be debated throughout the year and will look to engage the political discussion. The same is true of their employees, board members and other key stakeholders. But election activity needs to be thoughtfully approached and limited in scope. Register for this program and learn what 501(c)(3) organizations can do during an election year and how they can participate in the broader policy debates without violating strict prohibitions against supporting or opposing candidates for public office.

Structuring inbound investments for non-U.S. taxpayers presents a variety of trade-offs that must be carefully balanced such as income tax efficiency, minimizing withholding and filing obligations, producing post-mortem basis adjustment, avoiding anti-deferral regimes, continuation with tax treaties, and local law considerations. The appropriate structure - whether it be a trust, corporate partnership - or a combination, will also be informed by the type of U.S. investment being made, including financial assets, real estate or tangible personal property, such as artwork.

Real estate is a well-known investment strategy, with investment in high-cost projects typically pooled through real estate investment funds. Led by a sponsor who raises capital and sets the investment strategy, the structures of these funds can vary based on a range of tax considerations. As counsel to an investor or a sponsor in a real estate investment fund, you need to be well versed in the tax considerations inherently relevant to real estate investment fund structures to help your clients decide how to make tax-efficient and balanced decisions when forming a real estate investment fund or investing in such a fund.

Kicking off its 30th year, this popular, advanced program covers significant recent developments and how they affect estate planning practice. Featuring a nationally renowned faculty of estate planning lawyers, as well as Professor Jeffrey N. Pennell, this webcast is designed for sophisticated practitioners who need to stay up-to-date on changes in the field!

Although a partnership and an S corporation share many of the same characteristics, there are also distinct differences between these entities that will affect each shareholder’s tax burden, protection of personal assets, and control over policies. As counsel, you need to be well versed in the treatment of taxes and insulation of liability under each of these business structures to help your clients decide which best suits their ownership, management, and operational goals.

Owners of partnership interests frequently seek to sell or withdraw from a partnership through a cross-purchase with other owners or via cash redemption. Their economic considerations consist of cash, perhaps an installment obligation plus deemed relief of partnership debt. The client’s perception of the “net-after-tax” consideration received in selling a partnership interest after negotiating a term sheet or letter of intent may prove to be inflated and, in some instances, inflated substantially with hidden tax burdens. These “hidden” incremental tax costs to the partner selling part or all of a partnership interest may be sourced to "tax traps” within the partnership provisions pertaining to allocation of debt, cash and non-cash distributions and gain/loss characterization rules.

Nonprofit and charitable organizations must approach entity selection and formation decisions in an informed and careful manner. Not all nonprofits are charitable, and even when they are charitable, tax-exempt status is not guaranteed. Attorneys advising nonprofit organizations must engage clients in a multilayered analysis of their mission, their operations, and the organizational distinctions of nonprofits to align their needs and formation decisions. Once done, clients can then be counseled on the advantages and disadvantages of the four major state-based entity options as each has subtle tradeoffs. Only then can parties move on to discussing whether federal tax exemption is achievable and maintainable.

Holding S corporations and partnerships in trust have advantageous tax and estate planning opportunities. But passing S corporations and partnerships through trusts could interrupt cash flow and create tax traps if not done correctly. Register for this 90-minute video presentation discussing the issues affecting S corporation qualification and post-mortem trust funding, how tax distribution timing may disrupt blended families, ways to avoid net investment income tax annually and at sale, as well as multi-state resident issues and more!

High net worth clients, charitable organizations, and private foundations are increasingly looking for innovative, scalable, and sustainable solutions to intractable social problems. Funders are looking for new opportunities to deploy capital. A 2022 GIIN report estimates impact investment AUM was almost $1.2 trillion.
In response, charitable organizations are beginning to adopt innovative for-profit business models and strategies in pursuit of their charitable purpose. Meanwhile, for-profit entities include social impact in their strategic considerations as either risks to mitigate or opportunities to capitalize. The differences between for-profit and nonprofit organizations have begun to fade in response to these efforts. The impact investment space is roiling with innovation and creation. However, clarity of purpose and a firm understanding of emergent instruments are required to successfully navigate exciting developments.