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Insights


The weaponization ─ and subsequent monetization ─ of electronic data is clearly on display in this our second anniversary edition of Cyber Roundup. 

Boards of Directors and the not-for-profit organizations (NFPs) they serve have at least one thing in common: they come in all sizes and levels of sophistication. But regardless of their size or sophistication, all Boards are bound by a common duty to accept fiduciary responsibilities and provide operational oversight.

Accounting seeks to accurately describe the true economics of companies and their transactions. Since accuracy competes with achieving broad application, the degree of accuracy is not perfect. To manage gaps between the accounting story and the economic story, we use mechanisms such as EBITDA to better understand the economic story and make better decisions.

Under Internal Revenue Code (IRC) Section 274(a)(4), no deduction is allowed for an expense of a qualified transportation fringe benefit (QTFB) provided to an employee of a taxpayer. IRC Section 512(a)(7) provides that a tax-exempt organization’s unrelated business taxable income (UBTI) is increased by the amount of the QTFB expense that would be non-deductible under IRC Section 274.

In our continuing efforts to cover tax matters of interest to businesses with global relationships, the following articles are presented in the March 2019 edition of International Tax Insights.