EO Tax Journal

1 – Ron Schultz To Leave IRS

If you loved Del Boca Vista (remember those Seinfeld episodes?), you’ll love Boca Raton, Florida, where the ABA Tax Section will be having its winter meeting. For those lucky enough to go, I have the program schedule of the EO Committee. My plan is to listen to the tapes while watching the Super Bowl, although sometimes it can get confusing. Did Lois Lerner just score a touchdown? Did Ruth Madrigal intercept a pass?

3 – Samuel P. King, Judge and Critic of Hawaiian Charity, Dies at 94

No one new to the EO area should not know of the Bishop Estate. I’ve been fascinated by it ever since the seventies when I was assigned a ruling request by the estate. When it was denied, the estate’s lawyer went straight to Russell Long, then Chairman of Senate Finance, and got a rifle shot provision overturning the negative ruling. Now that’s having clout! Continue…

1 – IRS Personnel Changes

2 – The EOTJ Mailbag

3 – Weekend Reading

When it comes to governance, Mike Peregrine has been the man this fall, speaking at at least three programs. Today I’m sending along his outline that goes with his highly-acclaimed presentation. Continue…

The annual Priority Guidance Plan is out, and that’s always a good time to both look forward and look back. I used to blast the IRS and Treasury for how little guidance they put out each year, but what I found was the more I blasted them, the less they did. It was almost as if they had a meeting each year and said, “Let’s really irritate Streckfus and do less than we did last year.” (Not that I think they care what I think.) So now I come to praise them for their output, no matter how meager.

How about those proposed regulations under §§ 509 and 4943 regarding the new requirements for supporting organizations, as added by § 1241 of the Pension Protection Act of 2006? They may be a disaster for supported organizations if the payout rate goes down to 3%, but let’s not focus on the negative. A great effort.

And how about those final regulations under §§ 4965, 6011, and 6033 on excise taxes on prohibited tax shelter transactions and related disclosure requirements as added by § 516 of the Tax Increase Prevention and Reconciliation Act of 2005? A major accomplishment.

And how about those proposed regulations under § 7611 relating to church tax inquiries and examinations? A wonderful job. Congratulations to all.

So what if they only got three EO guidance items out. It could have been two or one or even none. Two proposed regs and one final reg is not something to sneer at. That’s a hat trick in hockey or soccer, not an easy thing to do.

My favorite item appears under Employee Plans, why there I don’t know since it seems like an EO item. EP is seeking final regulations under § 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations described in § 501(c)(9). Temporary regulations were issued on January 29, 1986. Now that’s what I call temporary — only 34 years and counting.

EO Excerpts from 2010-2011 Priority Guidance Plan Continue…

The IRS’ Steve Clarke frequently speaks on the Form 990, which is not surprising since he is the Form 990 project manager. I have had transcripts of his remarks this year — see Email Updates 2010-56 and 2010-165. He recently spoke again at the 2010 Western Conference on Tax Exempt Organizations, and I have had transcribed the portion of his remarks that go beyond his earlier comments.

2010 Form 990 Changes Continue…

A little bit of this and that today

1 – The EOTJ Mailbag

3 – Bidding Farewell Continue…