Archive for April, 2020

EO Tax Journal 2020-84

Paul Streckfus, April 30, 2020 at 5:36 am

1 – Editor’s Notebook

2 – Applicant Promoting the Exhibition, Breeding, and Training of Purebred Dogs Denied (c)(3) Exempt Status (Denial 202016023)

3 Second Circuit: Nothing ‘Scientific’ about Dog Shows to Merit (c)(3) Exempt Status (American Kennel Club v. Hoey)

4 – Tax Court: Nothing ‘Educational’ about Dog Shows to Merit (c)(3) Exempt Status (Ann Arbor Dog Training Club v. Commissioner)

5 – IRS: Dog Clubs May Be (c)(7)s, But Not (c)(3)s (Rev. Rul. 71-421) Continue…

EO Tax Journal 2020-83

Paul Streckfus, April 29, 2020 at 5:35 am

1 TEGE EO Council Seeking Volunteers for 512(a)(6) Comment Process

2 – In the News

3 – IRS Issues New Proposed UBIT ‘Silo’ Regulations for Nonprofits

4 – DOJ Alerts 11th Circuit of 6th Circuit’s Decision in Hoffman Properties

5 – Applicant Promoting the Interests of Franchise Owners Denied (c)(6) Status (Denial 202017028) Continue…

EO Tax Journal 2020-82

Paul Streckfus, April 28, 2020 at 5:22 am

1 – Editor’s Notebook

2 – In the News

3 – Meeting Guidance from New York Charities Bureau

4 Applicant Operating a Cemetery for the Benefit of Members Denied (c)(3) Status (Denial 202016020)

5 Applicant Providing Death Benefits to Pre-Selected Individuals and Their Families Denied (c)(3) Status (Denial 202017030) Continue…

EO Tax Journal 2020-81

Paul Streckfus, April 27, 2020 at 5:36 am

1 – Editor’s Notebook

2 – Commentary and Analysis of Proposed Section 512(a)(6) Regulations

A – Remarks of Alexander Reid and Chelsea Rubin, Morgan, Lewis & Bockius, Washington

B – Remarks of Rob Wexler, Adler & Colvin, San Francisco

C – Analysis Prepared by Steptoe & Johnson, Washington

3 – Form 1023 ‘Effective Date’ Instructions in Error

4 – Private Foundation’s Transfers to New Foundations Approved by IRS (PLR 202017026) Continue…

EO Tax Journal 2020-80

Paul Streckfus, April 24, 2020 at 5:07 am

1 – Editor’s Notebook

2 Outline of Explanation of Provisions and Summary of Comments

3 IRS, Treasury Issue Guidance for Applying UBTI ‘Silo’ Rules for Tax-Exempt Organizations by Identifying Separate Trades or Businesses (IR-2020-78)

4
Proposed Regs Address Debated Issues

5 Introductory Material to Proposed Regs and Call for Comments

6 IRS’s Reasons for Use of NAICS Codes Continue…