Archive for July, 2011

EO Tax Journal 2011-127

Paul Streckfus, July 29, 2011 at 5:55 am

The sad state of Treasury/IRS guidance is on full display today. First is a report on an organization called Americans Elect that claims to be a section 501(c)(4) section but appears to be a burgeoning political party. With the IRS unable or unwilling to address political activity by (c)(4)s, must we concede that this organization is being “operated exclusively for the promotion of social welfare”? The second is a letter expressing concern about “the continuing failure of the Treasury Department and the Internal Revenue Service to promulgate legally-defensible audit procedures for examining churches and organizations claiming to be churches.”

Next week I’ll summarize all the “solutions” I’ve received to the lack of guidance problem discussed the last two days. Until then, I’m left to continue to wonder why the relatively simple section 7611 regulations — proposed in 2009 — have not been finalized.

1 – Can a Political Party Be a (c)(4)?

2 – Missing In Action – Section 7611 Regulations

3 – How Much is Too Much? Continue…

EO Tax Journal 2011-126

Paul Streckfus, July 28, 2011 at 6:08 am

1 – The Lack of Guidance Conundrum – Part 2

2 – Groups Challenge Legality of IRS Regs as Failing to Properly Limit Campaign Activity by 501(c)(4) Organizations Continue…

EO Tax Journal 2011-125

Paul Streckfus, July 27, 2011 at 6:09 am

1 – The Lack of Guidance Conundrum

2 – ABA’s Annual Wish List

3 – Primer on Election Finance Continue…

EO Tax Journal 2011-124

Paul Streckfus, July 26, 2011 at 5:57 am

1 – CPA Characterizes Miller Memo as “Belated Acknowledgment that the Service Did Not Have a Legal Leg to Stand On”

2 – Proposed Revenue Procedure Addresses Ex Parte Communications

I’m told this proposed revenue procedure is a noncontroversial update of Rev. Proc. 2000-43, which makes one wonder why the IRS is setting it out in proposed form, rather than simply issuing an updated revenue procedure.  Continue…

EO Tax Journal 2011-123

Paul Streckfus, July 25, 2011 at 6:00 am

1EOTJ Mailbag

2 – New York Times’ Editorial on IRS’ Gift Tax Reversal

3 – Mystery Solved – Part 2

4 – Rare TAM Spotted Continue…