Archive for ‘PLRs, TAMs, and Denial Letters’

EO Tax Journal 2020-91

Paul Streckfus, May 11, 2020 at 5:18 am

1 – Editor’s Notebook

2 Income of Authority Engaged in Buying Commodities for Members Will Be Excluded from Gross Income under § 115(1) (PLR 202019026)

3 IRS Rules Transaction Involving Carbon Dioxide Offset Credits Resulting in Unusual Amount of Income Will Be One-Time Event and Not Derived from Active Conduct of Businesses under Section 501(c)(7) (PLR 202019027)

4 – Non-Member Income Results in Denial of (c)(7) Social Club Status (Denial 202015023) Continue…

EO Tax Journal 2020-90

Paul Streckfus, May 8, 2020 at 5:31 am

1 – Editor’s Notebook

2 Thirty Senators Support Legislation to Help Charitable Organizations

3 – Applicant Providing Death Benefits to Members Denied (c)(4) Status (Denial 202015024)

4 – Applicant Organizing Reunion and Gala Events that Benefit Family Denied (c)(3) Status (Denial 202016022)

5 – Applicant Providing Scholarships and Financial Aid to Family Members Denied (c)(3) Status (Denial 202016026) Continue…

EO Tax Journal 2020-89

Paul Streckfus, May 7, 2020 at 5:42 am

1 – The EOTJ Mailbag

2 – Editor’s Notebook

3 – SBA Extends ‘Safe Harbor’ Date for Returning PPP Loan Funds, Says Guidance Coming Before New Date

4 – New Treasury Department Rule Further Strengthens Religious Liberty Protections for PPP Loan Borrowers; Also Exempts Work Study Students from Employee Counts

5 – Applicant Organizing Recreational and Social Events for Members Denied (c)(3) Status (Denial 202016021) Continue…

EO Tax Journal 2020-88

Paul Streckfus, May 6, 2020 at 5:30 am

1 – Editor’s Notebook

2 – In the News

3 – Does Revocation 202001018 Deserve a Second Look?

4 – IRS Provides Temporary Guidance for Satisfying Section 147(f) Public Approval Requirement for Tax-Exempt Qualified Private Activity Bonds, Which Include 501(c)(3) Bonds (Rev. Proc. 2020-21)

5 – Operation of a Tavern in a Commercial Manner Outside Scope of Section 501(c)(3) (Denial 202016019) Continue…

EO Tax Journal 2020-87

Paul Streckfus, May 5, 2020 at 5:18 am

1 – The EOTJ Mailbag

2 – Editor’s Notebook

3 TEGE Exempt Organizations Update Webinar – Registration Open

4 Surviving the Pandemic: Using Endowment and Restricted Charitable Funds in the COVID-19 Crisis

5 – In the News

6 – Congressional Investigations: A Month In, Congress Signals Close Scrutiny of CARES Act and Paycheck Protection Program

7 – IRS Rules Services to Members Precludes (c)(6) Status (Denial 202018008) Continue…