Month: May 2017

Current News and Developments Editor's Notebook PLRs, TAMs, and Denial Letters

EO Tax Journal 2017-106

Paul StreckfusComments Off on EO Tax Journal 2017-106

1 – Editor’s Notebook

2 – Trump Says the IRS Regulates Churches Too Much. Here’s Why He’s Wrong

3 – Applicant Denied (c)(6) Status Because Its Activities Further Private Interests of Individual Members (Denial 201721020)

4 – Applicant Formed to Maintain a Building for Use by Various Local Fraternal Organizations Denied (c)(10) Status (Denial 201721021)

5 – Applicant Whose Activities Include Promoting Business Interests of Its Members, Improving Business in Area, and Providing Social Activities Denied (c)(3) Status (Denial 201721022)

Current News and Developments Focus on Courts Focus on IRS and Treasury PLRs, TAMs, and Denial Letters The EOTJ Mailbag

EO Tax Journal 2017-100

Paul StreckfusComments Off on EO Tax Journal 2017-100

1 – Has John Koskinen Lost His Mind?

2 – The EOTJ Mailbag

3 – Court Orders Lerner and Paz Depositions To Be “Confidential—Attorneys’ Eyes Only” Until Motion to Include Documents in the Public Record

4 – IRS Announces Three New Members for Advisory Committee on 
Tax Exempt and Government Entities (IR-2017-99)

5 – Applicant Providing Publishing Software for a Fee to Non-Exempt Local News Co-ops Denied (c)(3) Status (Denial 201720010)

PLRs, TAMs, and Denial Letters Program Announcements

EO Tax Journal 2017-99

Paul StreckfusComments Off on EO Tax Journal 2017-99

1 – UT Law School EO Program Announcement

2 – Applicant Providing a Funding Mechanism for Individuals to Raise Funds to Pay Their Student Loan Debt Denied (c)(3) Status (Denial 201718036)

3 – Applicant Whose Activities Result in Substantial Private Benefit to a For-Profit Subchapter S Corporation and Whose Earnings Inure to the Benefit of Its President Denied (c)(3) Status (Denial 201718039)

Current News and Developments Editor's Notebook Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2017-98

Paul StreckfusComments Off on EO Tax Journal 2017-98

1 – Editor’s Notebook

2 – Obama’s IRS Officials Should Be Forced to Testify on Improper Targeting

3 – Political Activities: Churches/Charities Should be Cautious

4 – Attorneys Say Time for IRS and Treasury to Clarify Treatment of Current Year Acquisition Costs re Charitable Contributions of Inventory

5 – Applicant Providing Archery Ranges and Coordinating Leagues for the Recreational Use of Its Members and the General Public Denied (c)(3) Status, But Retains (c)(4) Status (Denial 201718038)

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

EO Tax Journal 2017-96

Paul StreckfusComments Off on EO Tax Journal 2017-96

1 – The EOTJ Mailbag

2 – DC Bar EO Program Tomorrow

3 – My Favorite (c)(3) Organization

4 – Foundation’s Proposed Grant to Intermediary Will Constitute a Qualifying Distribution under Sections 4942(g)(1) and (3), But Intermediary’s Proposed Transfers of Waste to LLC Made Possible by Intermediary’s Use of the Proposed Grant Proceeds, Will Result in Indirect Acts of Self-Dealing under Section 4941 (PLR 201719004)

Current News and Developments Editor's Notebook Focus on IRS and Treasury PLRs, TAMs, and Denial Letters

EO Tax Journal 2017-95

Paul StreckfusComments Off on EO Tax Journal 2017-95

1 – EO Committee Met in Washington Last Friday

2 – Editor’s Notebook

3 – IRS Execs: Our Lives at Risk in Tea Party Case

4 – Appeals Changes Noted at ABA Tax Section Meeting

5 – Providing Pet Visitation as Therapy to Hospitalized Individuals Is in Furtherance of Organization’s Exempt Purposes under § 501(c)(3) (PLR 201719018)

Current News and Developments Transcripts (ABA EO Committee)

EO Tax Journal 2017-94

Paul StreckfusComments Off on EO Tax Journal 2017-94

1 – EO Committee to Meet Today in Washington

2 – Materials for “’Destroying’ the Johnson Amendment and the Future of 501(c)(3) Politicking”

3 – Materials for “The Current Climate for Nonprofit Enforcement”

4 – Materials for “Fostering Entrepreneurship and Innovation”

A – Bridging the Idea to Impact Gap: Incubators, Accelerators and Beyond

B – The Nature Conservancy: Investing in Conservation

C – Social Impact Bonds and Other Nonprofit/For-Profit Collaborations to Foster Innovation: Notes on Private Benefit Issues

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

EO Tax Journal 2017-93

Paul StreckfusComments Off on EO Tax Journal 2017-93

1 – Editor’s Notebook

2 – Written Materials for News from the IRS and Treasury

3 – Written Materials for News from Capitol Hill

4 – Two New EO Issue Snapshots Posted on irs.gov

A – IRC Section 4943 – Taxes on Excess Business Holdings

B – Deductibility of Contributions From Gaming Proceeds as Section 162 Business Expenses for Calculation of Unrelated Business Taxable Income by an Exempt Organization

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

EO Tax Journal 2017-92

Paul StreckfusComments Off on EO Tax Journal 2017-92

1 – The EOTJ Mailbag

2 – Trump’s Executive Order Addresses a Nonexistent Issue

3 – As Surfrider Foundation Heads to Capitol Hill, CRC Calls on IRS to Investigate Group’s Tax-Exempt Status

4 – Income of Organization Facilitating the Effective Reclamation, Revitalization, and Return to Economic Productivity of Abandoned or Foreclosed Real Estate Excludible from Gross Income under Section 115(1) and Contributions to It Deductible under Section 170 (PLR 201718001)

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

EO Tax Journal 2017-91

Paul StreckfusComments Off on EO Tax Journal 2017-91

1 – IRS Appropriation to Remain As Is thru September

2 – Why Don’t White Supremacists Pay Taxes?

3 – EO Program Announcement (Updated)

4 – Obama’s Non-Profit on Same Dubious Path First Blazed by Clinton Foundation

5 – No Self-Dealing Found between Foundation and For-Profit Corporation (PLR 201718002)

Current News and Developments Editor's Notebook Focus on Congress Focus on IRS and Treasury PLRs, TAMs, and Denial Letters Transcripts (Other)

EO Tax Journal 2017-87

Paul StreckfusComments Off on EO Tax Journal 2017-87

1 – Correction

2 – Editor’s Notebook

3 – Transcripts from February 24 Meeting of Joint TEGE Councils

4 – Critics Seek Relief from Conservation Easement Listing Notice

A – IRS Backs Away from Conservation Easement Crackdown

B – Partnership for Conservation Commends New IRS Notice, Calls for Further Revisions of Conservation Easement Donations

C – Notice 2017-10 (Pertaining to Syndicated Conservation Easement Transactions) Modified in Notice 2017-29

D – Member of Congress Seeks Delay of Effective Date of Notice 2017-10

5 – Operation of a Men’s Adult Baseball League Results in Revocation of Organization’s (c)(3) Status (Revocation 201717044)

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

EO Tax Journal 2017-85

Paul StreckfusComments Off on EO Tax Journal 2017-85

1 – Organization Comprised of Medical Institutions Battling IRS over Whether Income Received Qualified as Royalties or Commissions

2 – AICPA Provides IRS with Group Exemption Comments

3 – Applicant Providing Burial Assistance Funds to Members Denied under Section 501(c)(8) Because Not a Fraternal Beneficiary Association Operating under the Lodge System