Chapter 4 of the One Big Beautiful Bill (OBBBA) is titled “Investing In American Families, Communities.” Subchapter B of Chapter 4 is “Permanent investments in students and reforms to tax-exempt institutions.” That is where you will find “Modification of excise tax on investment income of certain private colleges and universities.” What is really amusing about this rewrite of IRC Section 4968 “Excise tax based on investment income of private colleges and universities” is that it applies to such a small number of institutions that you can identify them with a decent degree of certainty from publicly available information. The tax does not apply to state universities.
Contracts, Signing Bonuses, and the Substantial Presence Test
Amber Gray-Fenner, EA NTPI Fellow USTCP
In tighter job markets, recruits are often offered signing bonuses (and sometimes moving expenses) to join a firm. Sometimes construction workers temporarily relocate to jobs in other states while they are employed by the company that hired them in their home state. This article reviews some of the foundational tax concepts to consider when evaluating sourcing of income for state tax purposes.
