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

EO Tax Journal 2020-103

1 – Editor’s Notebook

2 In the News

3 – Updated FAQs on Employee Retention Credit and PPP Repayments

4 Homeowners’ Association Maintaining Common Areas Denied (c)(3) Status (Denial 202015026)

5 Condominium Association Denied (c)(4) Status, Based on Rev. Rul. 74-17 (Denial 202015028)

6 Condominium Association for a Medical Office Building Denied (c)(4) Status (Denial 202021024)

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

EO Tax Journal 2020-101

1 – Editor’s Notebook

2 – In the News

3 – Former Taxpayer Advocate Nina Olson Addressed Continuing Problems with the Form 1023-EZ

4 Trustee’s Distribution of Remaining Trust Principal to Remainder Beneficiaries Will Not Constitute an Act of Self-Dealing under Section 4941 (PLR 202021001)

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

EO Tax Journal 2020-99

1 – Quote of the Week

2 Editor’s Notebook

3 – In the News

4 – Call for Temporary 10% Payout by Foundations and DAFs

5 – Council on Foundations Urges More COVID-19 Legislation

6 Applicant’s Training of Disabled Veterans Incidental to For-Profit Activities (Denial 202015034)

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

EO Tax Journal 2020-97

1 – A Little EO Humor from McSweeney’s Daily Humor Website

2 – DC Bar Session Discusses Proposed Section 512(a)(6) Regulations

3 – SBA and Treasury Release Paycheck Protection Program Loan Forgiveness Application

4 Applicant Providing Consulting and Research Services for a Fee Denied (c)(3) Status (Denial 202020024)

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

EO Tax Journal 2020-94

1 – The EOTJ Mailbag

2 – In the News

3 – Steptoe Seminar Included Tips on Lobbying

4 – Upcoming EO Tax Program

5 SBA Issues FAQ Guidance on Good-Faith Certifications

6 Applicant Presenting Truck and Tractor Pulling Events Denied (c)(3) Status (Denial 202014022)

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

EO Tax Journal 2020-93

1 – Steptoe Presents Seminar on Section 512(a)(6) Proposed Regs

2 – IRS Says It Needs More Time to Complete Planning for an Improved IRS

3 – Investors in Firm’s Conservation Easement Partnership Alerted to IRS Audit Developments

4 Applicant Sending Representatives to Fishery Meetings Furthers Members’ Business Interests, Resulting in (c)(3) Denial (Denial 202017031)

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

EO Tax Journal 2020-92

1 – In the News

2 – Editor’s Notebook

3 Applicant that Maintains, Develops and Distributes Open Source Software Relating to Its Cryptocurrency Free to the Public Denied (c)(3) Status (Denial 202019028)

4 Applicant Serving Alcoholic Beverages to ‘Club Members’ Dining at a Restaurant Denied (c)(7) Status (Denial 202017037)

Editor's Notebook PLRs, TAMs, and Denial Letters

EO Tax Journal 2020-91

1 – Editor’s Notebook

2 Income of Authority Engaged in Buying Commodities for Members Will Be Excluded from Gross Income under § 115(1) (PLR 202019026)

3 IRS Rules Transaction Involving Carbon Dioxide Offset Credits Resulting in Unusual Amount of Income Will Be One-Time Event and Not Derived from Active Conduct of Businesses under Section 501(c)(7) (PLR 202019027)

4 – Non-Member Income Results in Denial of (c)(7) Social Club Status (Denial 202015023)

Editor's Notebook Focus on Congress PLRs, TAMs, and Denial Letters

EO Tax Journal 2020-90

1 – Editor’s Notebook

2 Thirty Senators Support Legislation to Help Charitable Organizations

3 – Applicant Providing Death Benefits to Members Denied (c)(4) Status (Denial 202015024)

4 – Applicant Organizing Reunion and Gala Events that Benefit Family Denied (c)(3) Status (Denial 202016022)

5 – Applicant Providing Scholarships and Financial Aid to Family Members Denied (c)(3) Status (Denial 202016026)

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

EO Tax Journal 2020-89

1 – The EOTJ Mailbag

2 – Editor’s Notebook

3 – SBA Extends ‘Safe Harbor’ Date for Returning PPP Loan Funds, Says Guidance Coming Before New Date

4 – New Treasury Department Rule Further Strengthens Religious Liberty Protections for PPP Loan Borrowers; Also Exempts Work Study Students from Employee Counts

5 – Applicant Organizing Recreational and Social Events for Members Denied (c)(3) Status (Denial 202016021)

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

EO Tax Journal 2020-88

1 – Editor’s Notebook

2 – In the News

3 – Does Revocation 202001018 Deserve a Second Look?

4 – IRS Provides Temporary Guidance for Satisfying Section 147(f) Public Approval Requirement for Tax-Exempt Qualified Private Activity Bonds, Which Include 501(c)(3) Bonds (Rev. Proc. 2020-21)

5 – Operation of a Tavern in a Commercial Manner Outside Scope of Section 501(c)(3) (Denial 202016019)

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

EO Tax Journal 2020-87

1 – The EOTJ Mailbag

2 – Editor’s Notebook

3 TEGE Exempt Organizations Update Webinar – Registration Open

4 Surviving the Pandemic: Using Endowment and Restricted Charitable Funds in the COVID-19 Crisis

5 – In the News

6 – Congressional Investigations: A Month In, Congress Signals Close Scrutiny of CARES Act and Paycheck Protection Program

7 – IRS Rules Services to Members Precludes (c)(6) Status (Denial 202018008)

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

EO Tax Journal 2020-85

1 – The EOTJ Mailbag

2 – Editor’s Notebook

3 NASCO Releases Annual Report on State Enforcement and Regulation

4 Form 1023 Paper Submission Transition Period Expired April 30

5 Breaking News: Nonprofits Are Not Eligible for the Main Street Lending Program

6 Independent Sector Asks Congress to Act

7 – NCN: DOL Issues Breathtakingly Cruel Guidance Inflicting Billions in Immediate Costs onto Charitable Organizations Struggling to Serve Their Communities

8 – SBA, Treasury to Evaluate Borrowers’ Eligibility for PPP Loans Amidst Criticism of Large Companies Obtaining Funds

9 – Applicant’s Social and Recreational Activities Result in Denial of (c)(3) Status (Denial 202015019)

10 Applicant’s Extensive Agricultural Activities Result in Denial of (c)(3) Status (Denial 202015027)