Editor's Notebook PLRs, TAMs, and Denial Letters

EO Tax Journal 2015-252

1 – Editor’s Notebook

2 – The Current and Future State of the EO Functions at the IRS

3 – Association’s Income is Excludable from Gross Income under Section 115 and Need Not File Form 990 Returns (PLR 201551001)

4 – Trust’s Income is Excludable from Gross Income under Section 115 (PLR 201551002)

5 – IRS Concludes Organization Is a Wholly Owned Instrumentality of Its Member Indian Tribal Governments and Hence Eligible to Receive Charitable Contributions (PLR 201551003)

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

EO Tax Journal 2015-250

1 – Follow-up on Social Clubs

2 – Naivete of Justice Anthony Kennedy on Display

3 – Applicant Failed to Describe Its Activities in Sufficient Detail to Permit the IRS to Determine Whether It Qualifies under Section 501(c)(4) (Denial 201552032)

4 – More Negative Comments on Proposed Donee Reporting Regs

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

EO Tax Journal 2015-247

1 – Correction

2 – Impact of PATH Act on IRS Office of Chief Counsel

3 – Politico Says White House Surrendered on ‘Dark Money’ Regulation

4 – Keeping the Perpetual in Perpetual Conservation Easements

5 – Conservation Easements and the Valuation Conundrum

6 – More Negative Comments on Proposed Donee Reporting Regs

Current News and Developments Focus on Congress The EOTJ Mailbag

EO Tax Journal 2015-244

1 – The EOTJ Mailbag

2 – Summary of FY 2016 Omnibus Appropriations Bill

3 – Brady, Hatch, Wyden Announce Deal to Provide Responsible Tax Relief for American Families, Job Creators & Entrepreneurs

4 – EO Excerpts from Section-by-Section Summary of Proposed “Protecting Americans from Tax Hikes Act  of 2015” (“PATH Act”)

Current News and Developments Focus on Congress Focus on Courts

EO Tax Journal 2015-243

1 – A (c)(3) Hedge Fund Hospital Operation?

2 – 17 House Republicans Urge No Appropriations for Proposed Donee Reporting Regs

3 – Legg v. Comm’r — Conservation Easement Donor Liable for Gross Valuation Misstatement Penalties

4 – Two Dozen Dark Money Groups Have Busted 50 Percent Cap on Politics at Least Once

5 – Conservative Website Blasts Planned Parenthood’s (c)(4)s for Heavy Political Spending

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

EO Tax Journal 2015-236

1 – EO Division Director Addresses CPAs

2 – IRS: Major Misimpressions and Inaccuracies about Purpose of Proposed Donor Regulations

3 – Transfer from Tax Exempt 2, Subsidiary of Tax Exempt 1, to Tax Exempt 1 of All of the Stock of Taxpayer, a For-Profit Corporation, Does Not Result in an Ownership Change of the Taxpayer within the Meaning of Section 382(g) (PLR 201549010)

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

EO Tax Journal 2015-234

1 – The EOTJ Mailbag

2 – Reaction to Proposed Schedule B Elimination

3 – Impact Investing Program Announcement 

4 – Applicant Operating for Substantial Commercial Purpose Denied (c)(3) Status (Denial 201548021)

5 – Homeowners Association Denied Based on Rev. Rul. 74-99 (Denial 201548020)