Amy Zelcer
Counsel
Amy Zelcer is a special tax counsel in the Tax Department. Amy works on U.S. federal corporate, partnership, and international tax matters, including domestic and cross-border financings, capital markets transactions, mergers and acquisitions, investments and restructurings.
Amy also maintains an active pro bono practice, representing not-for-profit/tax-exempt clients on a variety of matters, such as applying for and maintaining exemption from federal income tax and minimizing unrelated business taxable income.
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On Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax,” with retroactive effect to the date of its enactment.[1] Section 512(a)(7) was enacted pursuant to the 2017 U.S. tax legislation known as the … Continue Reading
Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”[1] Section 512(a)(7) was enacted pursuant to the 2017 U.S. tax legislation known as the “Tax Cuts and Jobs Act.” The provision required … Continue Reading
December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the “Code”), which requires tax-exempt employers to increase their unrelated business taxable income (“UBTI”) by amounts paid or incurred for qualified transportation fringe benefits provided to employees, including the provision of parking and public transportation benefits. Section 512(a)(7) was … Continue Reading
Early on December 2, 2017, the Senate passed the Tax Cuts and Jobs Act (the “Senate Bill”). This blog entry describes certain provisions of the Senate Bill that would have the most significant impact on the nonprofit community, including important differences between the Senate Bill and the prior version of the Senate bill and the … Continue Reading
Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress.[1] On Thursday, a detailed summary of the Senate Finance Committee’s proposal was released (the “Senate Markup”),[2] and the House Ways and Means Committee voted (in a 24-16, party-line vote) to … Continue Reading
On September 16, 2015, the IRS issued proposed regulations concerning the time and manner for donee organizations to file information returns that report required information about charitable contributions. The proposed regulations would implement an exception to the requirement that a taxpayer who claims a charitable contribution deduction for any contribution of $250 or more to … Continue Reading
Tax-exempt organizations that have had their tax-exempt status automatically revoked because of failure to file required annual returns for three consecutive years can follow new procedures for seeking reinstatement of their tax exemptions. The IRS released these procedures in Revenue Procedure 2014-11 on January 2, 2014. The Revenue Procedure, which is the first IRS guidance … Continue Reading
IRS Provides Guidance on Unrelated Business Income Tax Refunds
By Amanda H. Nussbaum and Amy Zelcer on Posted in IRS, Not-for-Profit, Tax-Exempt Organizations
Repeal of Unrelated Business Income Tax on Qualified Transportation Fringe Benefits
By Amanda H. Nussbaum and Amy Zelcer on Posted in Not-for-Profit
Inclusion of Qualified Transportation Fringe Benefits in UBTI: Guidance, Relief, and Rumors of Possible Repeal
By Amanda H. Nussbaum and Amy Zelcer on Posted in IRS
Updates for Tax-Exempt Organizations from the Senate Bill
By David Miller, Amanda H. Nussbaum, Elizabeth M. Mills, Steven Einhorn and Amy Zelcer on Posted in IRS
Updates for Tax-Exempt Organizations from the Senate Markup to the Tax Cuts and Jobs Act
By Amanda H. Nussbaum, Elizabeth M. Mills, Steven Einhorn and Amy Zelcer on Posted in Uncategorized
IRS Proposes Rules for Donee Charitable Donation Reporting
By Amy Zelcer on Posted in IRS Filings
IRS Introduces New Procedures for Reinstatement of Tax-Exempt Status
By Amy Zelcer on Posted in IRS Filings
