Archive for ‘PLRs, TAMs, and Denial Letters’

EO Tax Journal 2020-199

Paul Streckfus, October 13, 2020 at 5:48 am

1 – In the News

2 – Article of Interest

3 – Editor’s Notebook

4 – Applicant Denied (c)(3) Status Based on Substantial Non-Exempt Purpose (Denial 202041009) Continue…

EO Tax Journal 2020-198

Paul Streckfus, October 12, 2020 at 5:16 am

1 – Editor’s Notebook

2 – A Harsh Look at Private Operating Foundations

3 – Upcoming Programs

4 – Conservation Easements in the News

5 – IRS Rules Trust’s Income Is Excludable from Gross Income under Section 115(1) of the Code (PLR 202040007) Continue…

EO Tax Journal 2020-191

Paul Streckfus, October 1, 2020 at 5:30 am

1 – Editor’s Notebook

2 – Is It Time to Change the Section 4942 5% Payout Rule?

3 IRS Rules that Providing Whole Life Insurance to Members of VEBA Is a Permissible “Life Benefit” under Section 501(c)(9) (PLR 202039003)

4 – Comments of AICPA on Proposed Section 4960 Regulations Continue…

EO Tax Journal 2020-189

Paul Streckfus, September 29, 2020 at 5:31 am

1 – In the News

2 – Editor’s Notebook

3 Income from Online Placement Service Is Not a Royalty Payment under Section 512(b)(2) and Hence Subject to Tax under Section 511 (TAM 202039018) Continue…

EO Tax Journal 2020-188

Paul Streckfus, September 28, 2020 at 5:28 am

1 – In the News

2 – Editor’s Notebook

3 – An Analysis and Critique of Section 4941

4 – IRS Rules Proposed Grant Will Qualify as an Unusual Grant (PLR 202039020) Continue…