Month: March 2010

Focus on Congress Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2010-46

Paul StreckfusComments Off on EO Tax Journal 2010-46

A bit of this and that today. I expect to have a transcript of an interesting governance discussion that occurred last week featuring Fred Goldberg, Lois Lerner, and Suzanne McDowell if — and this is a big if — my transcriber — a big fan of Kentucky — can recover from Kentucky’s loss to West Virginia in the NCAA Men’s Basketball Tournament.

1 – Ten Tips for Deducting Charitable Contributions

2 – Six Important Facts about Tax-Exempt Organizations

3 – Grassley on New Hospital Provisions

4 – Providing Administrative Services Will Not Constitute Unrelated Trade or Business (PLR 201012052)

5 – Transfer of LLC Units to PF Will Not Constitute Self-Dealing or Recognition of Gain to Donors (PLR 201012050)

Focus on IRS and Treasury

EO Tax Journal 2010-41

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1 – Coming Attractions

2 – AHA Concerned About Schedule H “Flaws”
___________________

1 – Coming Attractions

27th Annual “Representing & Managing Tax-Exempt Organizations” Conference
April 22-23, 2010, Washington, D.C.

Focus on Congress Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2010-40

Paul StreckfusComments Off on EO Tax Journal 2010-40

My bookshelf

I kind of skimmed Sarah Palin’s book, Going Rogue, so I shouldn’t comment on what I didn’t really read. From another source, I learned that Palin has ancestors from County Roscommon in Ireland. Well, my mother’s family goes back to County Roscommon, too. Who knows, I may be a distant cousin. If Palin becomes President, someone remind her of that. I’d like to be an ambassador, preferably to a country where the living is good and the toasts never end.

Editor's Notebook Focus on IRS and Treasury

EO Tax Journal 2010-38

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ABA’s Recommendations for More PRI Examples

I’m reprinting below the recent comments of the ABA’s Tax Section. I’ve also reprinted my prior comments on the ABA’s earlier recommendations. I continue to have concerns that we will have an “anything goes” situation with private foundations and their PRIs. Who determines a below-market rate of interest and how? Who determines that conventional sources of financing are not available and how? Who determines that no for-profit investors are interested and how? Should equity investments and “equity kickers” be allowed in any instances? Doesn’t the potential for high profits attract venture capital? Should foundations become owners of the ventures they are financing?

Transcripts (ABA EO Committee)

EO Tax Journal 2010-37

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Well, it’s done. All the transcripts of the January 22 meeting of the EO Committee of the ABA’s Tax Section have been completed with today’s transcript on social clubs. For those suffering withdrawal pains, they’ll do it all again in May.


Update on Social Clubs and Section 501(c)(7)

Transcripts (ABA EO Committee)

EO Tax Journal 2010-35

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I mentioned last Friday that I read obituaries. Louise McKnew died on February 23 from pneumonia at age 71. I hardly knew her. About all I knew about her was that she was a neighbor and that she was a member of the D.C. Bar. The only reason I knew she was a member of the D.C. Bar was because our Mensa mailman delivers all mail from the D.C. Bar to me, so I got Louise’s D.C. Bar mail and would give it to her.

Editor's Notebook Transcripts (ABA EO Committee)

EO Tax Journal 2010-34

Paul StreckfusComments Off on EO Tax Journal 2010-34

We’ll probably be able to wrap up transcripts of the January 22 EO Committee meeting this week. Today I have Part 2 of the panel on Foreign Activities and Withholding. Next out of the chute will be the panel on Accounting Developments Affecting Charities and 990 Reporting. We’ll complete our cavalcade of transcripts with the panel on Section 501(c)(7) Social Clubs. What an exciting way to start March!

In response to EO Tax Journal 2010-29, a retired EO agent sent along these comments:

“Back in 1975, when I signed on to EO, we really had a group of passionate revenue agents who took the time and made an effort to know and apply the law. Everyone was so committed to making the right decision and correctly interpreting the law — so what happened? IRS training for revenue agents went downhill as the senior agents retired and management thought EO audits were not worthwhile — no big dollar adjustments, a silly change/no change letter, and not so much as a warning about better behavior or else!

“But then, so it seems, IRS tried a different tack. We won’t audit EOs as much, but we will make the Form 990 more informative to the public. So now this document can be viewed by the public and everyone will have a clear idea of what the exempt organization does and where its money comes from and how it is spent. Oh my — as a member of various charitable/civic/community organizations I’m asked to assist in the preparation of the 990 as soon as they find out I am a former EO revenue agent. I had to laugh the first time I tried to get my arms around that return again after several years. It is so overly complicated for a smaller organization that just meets the filing requirement. Trying to categorize income and expenses according to the form was exhausting. And then when a small 501(c)(3) has to file Schedule A and B (I think that’s right) because they have one or two very generous donors, more drama. ‘Do I really have to put Mrs. X’s name down?’ And so it goes.