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Francis J. Mirabello
Partner - Philadelphia
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On July 12, 2004, New Jersey’s Domestic Partnership Act (DPA) went into effect, changing the legal landscape that employers and New Jersey health insurance providers must navigate with respect to employee protections and benefits... more
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The Internal Revenue Service has opened a window of opportunity to convert existing net income with make-up charitable remainder unitrusts (“NIMCRUTs”) and net income charitable remainder unitrusts (“NICRUTs&rd... more
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Francis Mirabello
On December 9, 1998, the Internal Revenue Service released final regulations governing charitable remainder trusts (the Final Regulations). This paper summarizes the Final Regulations, which took effect December 10, 1998. In... more
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The Internal Revenue Service recently issued Notice 98-20, which explains how the recent changes in capital gains rates affect capital gains distributions from charitable remainder trusts. The IRS plans to issue regulations tha... more
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Francis Mirabello
As you may be aware, the Pennsylvania General Assembly recently passed the Charitable Gift Annuity Exemption Act (the Act), which exempts the issuance of qualified charitable gift annuities by qualified charities from the Pennsy... more
Morgan Lewis Title | White Paper
Francis Mirabello
In December 1995, Congress passed the Philanthropy Protection Act of 1995 (the PPA), which clarifies the federal and state securities law registration and disclosure responsibilities of charities managing funds that commingle sp... more
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Francis Mirabello, Joseph O'Connor, Jr.
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John J. Lombard, Jr., John F. Bales III
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Thomas McCorriston, Jr.
This White paper discusses the limitation imposed by the "earnings-stripping" provisions of the Revenue Reconciliation Act of 1989 on the federal income tax deductibility of interest paid or accrued by corporate taxpayers to a r... more
