Firing a Key Employee of a Not For Profit Organization
Jun 28, 2014
Perhaps the most difficult decision for a not for profit organization is firing a Key Employee
How can this be done politely, professionally and while creating a minimum of negative energy within ...
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Taxation and Compliance for non-US Entities owned by Non-US Trusts Taxable to US Grantors
Apr 10, 2014
Overview Trustees of Non-US Grantor Trusts ("NUSGT") may wish to invest in more than US based business and investment opportunities for a variety of reasons. Accordingly it is important for the Gran...
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Moving your Business to Florida in a Tax Free Transaction
Jul 13, 2011
If you are tired of over taxation and over regulation in your state it actually may be better in Florida. The beaches and golf are probably better around February as well.
This brief summary outlin...
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Can a Public Charity Actually form a Structure to become involved in Political Activities?
Jul 12, 2011
In PLR201127013, the IRS provides a road map for a public charity that is interested in becoming more involved in politics. While 501(c)(3) organizations are limited in their ability to be involved in ...
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Reinstating Tax-Exempt Status if you lose your Exemption do to Automatic Revocation
Jul 06, 2011
The IRS recently published a list of over 275,000 exempt organizations who have lost their status for failing to comply with annual reporting requirements. The IRS usually provides noticesto exempt...
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Making Gifts of Real Property to Charity by Deed in Florida
Mar 29, 2011
Florida Statues require that in most instances real property must be made by a written instrument commonly known as a deed . Typically, deeds must be signed by the grantor of the interest in real prope...
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Employee vs. Independent Contractor - the 7 Factors Courts Apply
Mar 29, 2011
The 7 Factor Test
In Ewens (2) which party invests in work facilities the worker used; (3) the worker's opportunity for profit or loss; (4) whether the principal can discharge the worker; (5) whet...
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Employee or Independent Contractor? – The 20 Factor Test
Mar 29, 2011
Whether a person is or is not an employee is based on the facts governing the relationship between the person requiring the services and the person requesting the services . At common law an employer-e...
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Annual Exclusion Gifts of Member Interests in Limited Liability Companies Part IV
Mar 29, 2011
The Property Alternative
Free Transferability
There is some but limited guidance in this area. The IRS has issued a number o private letter rulings and TAMs discussing permitted restrictions, but t...
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Annual Exclusion Gifts of Member Interests in Limited Liability Companies Part III
Mar 29, 2011
The Income Alternative
In the underlying Tax Court case, the Court looked at the following factors as indicative of a right to enjoy the income from property :
1. The entity had a the ability to ge...
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