Archive for ‘PLRs, TAMs, and Denial Letters’

EO Tax Journal 2017-205

Paul Streckfus, October 20, 2017 at 4:27 am

1 – The EOTJ Mailbag

2 Two Members of Congress Say IRS Agents’ Calculation of Overlapping Charitable Contribution Deductions and Net Operating Loss Carryovers Needs Treasury Review

3 Certain Income of a Trust Is Subject to Unrelated Business Income Tax (TAM 201741019) Continue…

EO Tax Journal 2017-201

Paul Streckfus, October 16, 2017 at 4:22 am

1 - Editor’s Notebook

2 – Bruce Hopkins’ Summary of Section 514 Private Letter Ruling

3 – ABA Section of Taxation Seeks More Time To Comment on New Form 1024-A

4 – Reviewed Audit Technique Guides Released by IRS

5 – Applicant Providing Benefits to Help Members in Event of Death of a Relative Denied (c)(3) Status (Denial 201740023) Continue…

EO Tax Journal 2017-200

Paul Streckfus, October 13, 2017 at 4:22 am

1 - Editor’s Notebook

2 – Remedies and the Parsonage Allowance

3 - Universal Charitable Giving Act of 2017 (H.R. 3988) Introduced by Rep. Mark Walker, R-N.C., on October 4, 2017

A – Independent Sector Statement on the Universal Charitable Giving Act

B – National Council of Nonprofits Statement on the Universal Charitable Giving Act

4 – Agreement with Developer, Whereby Initial Fees and Expenses Are Borne by Developer, To Be Later Paid or Reimbursed by Foundation, and Whereby a Success Fee May Be Payable upon Completion of the Rezoning Process, Will Not Give Rise to Section 514(c) Acquisition Indebtedness, Nor Will Receipt of Lease Proceeds from the Property Be Includible in Foundation’s Unrelated Business Taxable Income under Section 512(a) (PLR 201740002) Continue…

EO Tax Journal 2017-195

Paul Streckfus, October 6, 2017 at 4:52 am

1 – Correction

2 – Program Reminders

3 – New TIGTA Report on ‘IRS Scandal’

4 – Latest TIGTA Report Appears to Undermine Earlier Findings

5 – Professorial Comments on TIGTA Report

6 – Applicant Operating as a Mortgage Broker Denied 501(c)(3) Status(Denial 201739016) Continue…

EO Tax Journal 2017-194

Paul Streckfus, October 5, 2017 at 4:11 am

1 – Quote of the Week

2 – Editor’s Notebook

3 – Article of Interest

4 Group Says New IRS Guidelines Deter Private Land Conservation, Thwart Congressional Intent

5 – Condominium Association Denied (c)(4) Status (Denial 201736027) Continue…