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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.
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.
Knowledge or experience in preparing or reviewing Form 990-T, or experience as controller, analyst, CFO or investment manager.
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.
Rich Ruvelson has more than 30 years of experience in providing tax services to non-profit clients, including labor unions, multiemployer benefit plans, private foundations and a wide variety of public charities, including private colleges, hospitals, religious and cultural organizations, their supporting organizations and other affiliates. He has worked closely with both small and large clients on a wide range of non-profit issues including tax exemption, unrelated business income tax, public support, charitable giving and substantiation, independent contractor issues, and Form 990, Form 990-PF and Form 990-T reporting. Outside of public accounting, he has served as Tax Manager of the University of Washington and Treasurer and Finance Director of The California Endowment. He has spoken on a variety of nonprofit tax issues at a number of accounting and nonprofit industry conferences, taught at firm internal and external training and, also, taught Law of Tax-Exempts in the MBT program of the University of Minnesota’s Carlson School of Management. Rich is licensed to practice law in Minnesota.