Month: February 2014

Focus on Congress Focus on IRS and Treasury The EOTJ Mailbag

EO Tax Journal 2014-44

Paul StreckfusComments Off on EO Tax Journal 2014-44

1 – The EOTJ Mailbag

2 – Lois Lerner’s Ode to House Republicans

3 – Republican IRS Investigations Have Cost at Least $14 Million — and Counting

4 – Yesterday’s House Oversight Hearing

5 – EO Excerpts from February 26 Prepared Testimony of IRS Commissioner John Koskinen to the House Appropriations Committee

6 – EO Excerpts from February 26 Prepared Testimony of Nina Olson, National Taxpayer Advocate, to the House Appropriations Committee

7 – Treasury’s Latest Letter to Ways and Means Chairman Camp

8 – Published Comments on Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities

9 – Comments of 12 Organizations on Proposed (c)(4) Regs

10 – Comments of 21 EO Attorneys on Proposed (c)(4) Regs

Focus on Congress Focus on IRS and Treasury

EO Tax Journal 2014-43

Paul StreckfusComments Off on EO Tax Journal 2014-43

1 – Yesterday’s House Oversight Hearing

2 – Today’s House Oversight Hearing

3 – House Oversight Committee Seeks Recall of Lois Lerner

4 – Lawyer to Darrell Issa: Lois Lerner Facing Threats

5 – Camp Demands Lerner Emails from IRS

6 – Statement of Administration Policy

7 – EO Provisions in Camp’s Tax Reform Act of 2014

Current News and Developments Focus on Congress Focus on IRS and Treasury The EOTJ Mailbag

EO Tax Journal 2014-42

Paul StreckfusComments Off on EO Tax Journal 2014-42

1 – The EOTJ Mailbag

2 – The Wit and Wisdom of Professor John Colombo — Read if You Dare

3 – Witnesses for Today’s House Oversight Hearing

4 – February 27 Deadline for Comments on Proposed (c)(4) Regs Is Almost Here — Thank God

A – Liberals vs. the IRS

B – IRS Proposed Rules For Nonprofits Alarm Conservatives and Liberals Alike

C – Obama’s Proposed IRS Rules to Limit Tax-Exempt Status Concern Liberals, Too

D – Compendium of Commentary on Proposed (c)(4) Regulations

Current News and Developments PLRs, TAMs, and Denial Letters The EOTJ Mailbag

EO Tax Journal 2014-41

Paul StreckfusComments Off on EO Tax Journal 2014-41

1 – The EOTJ Mailbag

2 – IRS Scandal Has Obama Fingerprints All Over It, Experts Say

3 – Comprehend if You Can (PLRs 201407021 and 201407023)

4 – Community Trust and a Corporation Will Be Treated as a Single Entity under  § 1.170A-9(f)(11)(i) and Their Funds as a Single Entity Community Trust under § 1.170A-9(f)(11)(ii) (PLR 201403016)

Current News and Developments PLRs, TAMs, and Denial Letters The EOTJ Mailbag

EO Tax Journal 2014-39

Paul StreckfusComments Off on EO Tax Journal 2014-39

1 – The EOTJ Mailbag

2 – Ruth Madrigal to Join Sunita Lough and Judy Kindell Next Friday in Baltimore

3 – EO Scam Included in IRS’s 2014 ‘Dirty Dozen’ List

4 – Parent Company of Healthcare System Held Not a § 170(b)(1)(A)(ii) Educational Organization and Hence Not a § 514(c)(9)(C) Qualified Organization for Purposes of Determining if Income Parent Derived from Investment Partnerships Is Excluded from UBTI (TAM  201407024)

5 – Retroactive Relief Denied to Three Organizations (TAMs 201407016, 201407017, and 201407018)

Current News and Developments Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2014-38

Paul StreckfusComments Off on EO Tax Journal 2014-38

1 – Proposed (c)(4) Regs Described as “Draconian” and “Ludicrous”

2 – Full Speed Ahead, Says the New York Times

3 – EO Determination Letters Remain Eligible for Expedited Handling (Rev. Proc. 2014-19)

4 – UBIT Ruling Rehashes Old Cases (PLR 201407022)

5 – Trade Association’s Activities Not Subject to UBIT (PLR 201406020)

Current & Quotable Transcripts (ABA EO Committee)

EO Tax Journal 2014-34

Paul StreckfusComments Off on EO Tax Journal 2014-34

1 – Quotes of the Week

2 – Background Materials for Small Charities Discussion

A – Reinstatement Procedures for Automatically Revoked Exempt Organizations

B – New Retroactive Reinstatement Process(es)/Opportunities Under Revenue Procedure 2014-11

C – Small Nonprofit Consultation Checklist

D – Nonprofit Board Duties: Program Oversight

Current News and Developments Editor's Notebook Focus on IRS and Treasury Transcripts (ABA EO Committee)

EO Tax Journal 2014-33

Paul StreckfusComments Off on EO Tax Journal 2014-33

1 – Latest IRS Outrage?

2 – DC Bar’s Part 3 of 5 Exempt Organizations Tax Series: The Regulation of Candidate-Related Political Activity

3 – ECFA Encourages More Freedom and Greater Clarity in Political Activity Rules

4 – ABA’s EO Committee’s January 24 Meeting: News from the IRS and Treasury (Part 2)

Current News and Developments Focus on Congress The EOTJ Mailbag

EO Tax Journal 2014-31

Paul StreckfusComments Off on EO Tax Journal 2014-31

1 – Quote of the Week

2 – The EOTJ Mailbag

A – Reinstatement Applications Update

B – Time for Exam Agents to Work Applications?

3 – House Ways and Means Republicans Report Out H.R. 3965

A – Camp Opening Statement: H.R. 3865, “Stop Targeting of Political Beliefs by the IRS Act of 2014”

B – Ways and Means Committee Votes to Block IRS Regulations Designed to Put Conservative Groups Out of Business

C – Ranking Member Sander Levin Opening Statement at Mark-up of H.R. 3865

D – JCT Description of H.R. 3865

E – Proposed Amendment to H.R. 3865

F – JCT Description of Proposed Amendment

G – Eleven Groups Oppose H.R. 3865

Current News and Developments The EOTJ Mailbag Transcripts (Other)

EO Tax Journal 2014-30

Paul StreckfusComments Off on EO Tax Journal 2014-30

1 – The EOTJ Mailbag

A – Minimal Corporate Tax on For-Profit Political Organizations?

B – More on Minimal Corporate Tax on For-Profit Political Organizations?

C – Existing (c)(4) Rules Were Not the Problem at IRS — Fear of Citizens United Was!

2 – What’s Coming from a Tax Policy Standpoint (Ruth Madrigal)

Focus on Congress Focus on Courts PLRs, TAMs, and Denial Letters The EOTJ Mailbag

EO Tax Journal 2014-29

Paul StreckfusComments Off on EO Tax Journal 2014-29

1 – The EOTJ Mailbag

2 – Gowdy, Jordan, Chaffetz Press AG on President’s IRS Comments

3 – Levin, Cummings to IRS: How Much Have Investigations Cost the Agency?

4 – Cause of Action Sues IRS over Proposed Regulations Affecting Nonprofits

5 – IRS Rules Tax-Exempt Status of Organization Accepting Conservation Easements Should Be Revoked

Editor's Notebook Focus on Congress Focus on IRS and Treasury

EO Tax Journal 2014-26

Paul StreckfusComments Off on EO Tax Journal 2014-26

1 – My Observations on Yesterday’s House Hearing

2 – Prepared Written Testimony of Catherine Engelbrecht, True the Vote, King Street Patriots (First Witness)

3 – Prepared Written Testimony of Cleta Mitchell, Foley & Lardner (Second Witness)

4 – Prepared Written Testimony of Becky Gerritson, Wetumpka TEA Party (Third Witness)

5 – Prepared Written Testimony of Jay Sekulow, American Center for Law and Justice (Fourth Witness)

6 – Obama’s IRS ‘Confusion’

Current News and Developments Focus on Congress Focus on IRS and Treasury

EO Tax Journal 2014-25

Paul StreckfusComments Off on EO Tax Journal 2014-25

1 – House Oversight Hearing Mostly Deja Vu

2 – Rep. Charles Boustany’s Opening Statement

3 – Excerpts from Written Testimony of IRS Commissioner John Koskinen

4 – Rep. Dave Camp Blasts Treasury & Lois Lerner for Developing 501(c)(4) Rules

A – The ‘Off-Plan” Email

B – ‘Media Attention’ Emails — Selected Excerpts

5 – More Conservative Groups Protest IRS Political Activity Rule

Current News and Developments Editor's Notebook Focus on Congress PLRs, TAMs, and Denial Letters The EOTJ Mailbag

EO Tax Journal 2014-22

Paul StreckfusComments Off on EO Tax Journal 2014-22

1 – Quote of the Week

2 – The EOTJ Mailbag

3 – Editor’s Notebook

A – Hill Republicans v. IRS

B – Me v. IRS

4 – Republicans Turn Up IRS Rhetoric as Elections Loom

5 – McConnell Calls on IRS Commissioner to Resist Obama Administration Efforts to Muzzle Free Speech

6 – Camp Requests All Documents on Proposed Changes to 501(c)(4) Rules

7 – What Part of No Don’t You Understand?

A – DOJ’s Response to Jordan

B – Jordan’s Rejoinder to DOJ

8 – Website Meets Section 1.513-4 Definition of Term ‘Periodical’ (PLR 201405029)