Hybrid Structures – Practitioners’ Perspectives
What follows is a transcript of the October 1 remarks of Victoria Bjorklund, Simpson Thacher & Bartlett, New York, and Robert Keatinge, Holland & Hart, Denver, as delivered at the 2012 NAAG/NASCO conference in Silver Spring, Maryland. Their slides appear at the end of the transcript.
Month: November 2012
EO Tax Journal 2012-197
1 – The Future of Philanthropy
2 – Support from Bloomberg Businessweek?
3 – Latest SOI Bulletin Has Article on EOs
4 – LA Times’ Article Discusses State Efforts at Identifying Campaign Donors
5 – Real Estate Roundtable Supports ‘Fractions Rule’ Guidance re Partnership Allocations under Section 514(c)(9)(E)
6 – IS Mounts Lobbying Effort to Protect the Contribution Deduction
7 – Charitable Giving Coalition News Release and Letter
EO Tax Journal 2012-196
1 – End November in Los Angeles
2 – Then January in Orlando
3 – Finally, February in New York (Not a Typo)
EO Tax Journal 2012-194
1 – Come One, Come All
2 – More on 2012-2013 Priority Guidance Plan
3 – Cheerleaders Get No Cheers from the IRS (Revocation 201245025)
EO Tax Journal 2012-193
1 – Late-Breaking News: 2012-2013 Priority Guidance Plan Released
2 – Recent EO Cases in Litigation
3 – Declaratory Judgment Revocation Action Will Be Reviewed De Novo and Not Limited to the Administrative Record
EO Tax Journal 2012-192
1 – Is It Me or Select Check? Mystery Solved?
2 – Sandy Deja’s Latest Auto-Rev Report
3 – Berman and Company’s Response to Bloomberg Article
4 – Petraeus Sex Scandal Uncovers Charity Scam?
5 – FFRF Sues IRS to Enforce Church Electioneering Ban
EO Tax Journal 2012-191
1 – Is It Me or Select Check?
2 – Nonprofit Companies Swimming in Profit?
3 – The Blending of the For-Profit and Nonprofit Sectors
EO Tax Journal 2012-190
Health Care Tax Developments (Part 2)
EO Tax Journal 2012-189
1 – The EOTJ Mailbag (Comments on PLR 201244020)
2 – Health Care Tax Developments (Remarks of IRS’s Steve Clarke and Garrett Gluth)
EO Tax Journal 2012-188
1 – PGP — MIA?
2 – DAFs — Blessing or Bane for Charities?
3 – ‘Charity’ Walks and Runs — Another Net Drain to Nonprofits?
4 – Private Foundation Gets 11 Rulings for Its $10,000 (PLR 201244020)
EO Tax Journal 2012-187
1 – Four More Years Does Not Bode Well for EO Administration by IRS
2 – ‘Appalling Abuse of Tax-Exempt Status’ at Issue in Humane Society’s Complaint to IRS about Rick Berman
3 – CREW Seeks Investigation of Catholic Bishops for Church Politicking
4 – IRS Expedites Charity Applications, Urges Use of Existing Charities
EO Tax Journal 2012-186
1 – Is IRS a Modern-Day Pinocchio?
2 – IRS’s Preston Quesenberry and Treasury’s Ruth Madrigal Address Health Lawyers on Section 501(r) (Part 2)
EO Tax Journal 2012-185
1 – Comings and Goings
2 – IRS’s Preston Quesenberry and Treasury’s Ruth Madrigal Address Health Lawyers on Section 501(r) (Part 1)
EO Tax Journal 2012-184
Navigating an IRS Audit
What follows is an edited transcript of the October 19 remarks of Russell Renwicks, IRS Group Manager, Baltimore, and Virginia Puddister, IRS Revenue Agent, Baltimore, as delivered at the annual ALI-CLE program on Tax Exempt Organizations. The moderator of the session is Celia Roady of Morgan Lewis & Bockius, Washington.