1 – Editor’s Notebook
2 – Taxpayer’s Income Accrues to County of State under Section 115(1) and Contributions Qualify under Section 170(c)(1) (PLR 202437001)
PLRs, TAMs, and Denial Letters
EO Tax Journal 2024-141
1 – The EOTJ Mailbag
2 – Editor’s Notebook
3 – IRS Approves Foundation’s Scholarship and Educational Grant Procedures
4 – Nonprofit Explorer Now Shows Which Organizations Are Trending
EO Tax Journal 2024-137
1 – Upcoming Program
2 – In the News
3 – Editor’s Notebook
4 – Scholarship Procedures Approved under Section 4945 (Ruling Letter 202434017)
EO Tax Journal 2024-136
1 – In Memoriam
2 – In the News
3 – Article of Interest
4 – Editor’s Notebook
5 – Condominium Association Denied (c)(4) Status (Denial 202434013)
EO Tax Journal 2024-131
1 – The EOTJ Mailbag
2 – Editor’s Notebook
3 – In the News
4 – ABA EO Committee to Meet Virtually
5 – IRS Approves Acceleration of Charitable Split-interest Lead Trust’s Last Two Annuity Payments (PLR 202432004)
EO Tax Journal 2024-130
1 – The EOTJ Mailbag
2 – Editor’s Notebook
3 – Foundation and DAF Payout Reform Would Unlock $339 Billion for Working Charities over the Next Three Years
4 – EO Must Apply a Reasonable, Good Faith Interpretation of the Section 52 Controlled Group Rules in Determining ERC Eligibility (CCA 202430007)
EO Tax Journal 2024-128
1 – Editor’s Notebook
2 – AAUW Releases Statement on Do No Harm Settlement
3 – Private Foundation’s Set-Aside Request Approved by IRS (LTR 202432022)
4 – IRS Encourages Organizations Planning to Claim Elective Pay to Complete Pre-filing Registration Now for 2023 Tax Year (IR-2024-210)
EO Tax Journal 2024-126
1 – Editor’s Notebook
2 – In the News
3 – DEI Update: State Attorney Generals Battle It Out
4 – Applicant Compensating Student Athletes Denied (c)(3) Status Based on Serving Private Interests (Denial 202432020)
EO Tax Journal 2024-112
1 – Quote of the Week
2 – In the News
3 – NACUBO Urge House Members to Withdraw H.R. 8913 and H.R. 8914
4 – Editor’s Notebook
5 – Applicant Facilitating Name, Image, and Likeness (NIL) Payments to High School or College Athletes Denied (c)(3) Status (Denial 202428008)
EO Tax Journal 2024-106
1 – Editor’s Notebook
2 – The EOTJ Mailbag
3 – IRS Grants an Extension of Additional Five Years under Section 4943(c)(7) for Disposing of Certain Excess Business Holdings (PLR 202426013)
EO Tax Journal 2024-105
1 – Editor’s Notebook
2 – Recent Articles of Interest
3 – In the News
4 – IRS Approves Scholarship and Grant Procedures under Section 4945(g) (Ruling 202426018)
EO Tax Journal 2024-64
1 – Editor’s Notebook
2 – Applicant Providing Athletes an Opportunity to Earn NIL Revenue While Partnering with Local Charities Denied (c)(3) Status (Denial 202416015)
3 – Hearing on Proposed DAF Regulations Extended
EO Tax Journal 2024-59
1 – Editor’s Notebook
2 – Stipulated Decision in Free Sacred Trinity Church
3 – Income Received by Section 501(c)(6) Association for Certifying Facilities to Third-Party Standards Is Not Subject to UBIT (PLR 202415003)
EO Tax Journal 2024-55
1 – Editor’s Notebook
2 – Applicant Denied (c)(3) Status Based on Benefits to Student Athletes (Denial 202414007)
EO Tax Journal 2024-51
1 – Editor’s Notebook
2 – ABA’s EO Committee to Meet May 3 in Washington
3 – Taxpayer’s Income from Underwriting Reinsurance Policies for Authority Is Excludable from Gross Income under § 115(1) (PLR 202413009)
EO Tax Journal 2024-29
1 – Editor’s Notebook
2 – IRS Approves Private Foundation Scholarship Program (Letter 202407006)
3 – Comments of the Philanthropy Roundtable on the Proposed Section 4966 DAF Regulations
4 – Comments of the Council on Foundations on the Proposed Section 4966 DAF Regulations
EO Tax Journal 2024-25
1 – In the News
2 – Editor’s Notebook
3 – Comments of SIFMA on Section 4966 Proposed DAF Regulations
4 – IRS Rules Trust’s Income Excludable from Gross Income under Code Section 115(2) (PLR 202405002)
EO Tax Journal 2024-21
1 – Second Quote of the Week
2 – In the News
3 – Editor’s Notebook
4 – Applicant Denied (c)(3) Status Because Open-Source Software Does Not Further a Charitable Purpose
EO Tax Journal 2024-3
1 – In the News
2 – Editor’s Notebook
3 – Homeowners Association Consisting of Owners near Lake Denied (c)(3) Status(Denial 202349013)
4 – Georgetown Law School to Present Private Foundation Summit 2024
EO Tax Journal 2024-2
1 – Editor’s Notebook
2 – In the News
3 – New York Court Holds NYAG Had Probable Cause to Investigate NRA
4 – Applicant Whose Members Share Health Care Costs Denied (c)(3) Status (Denial 202346033)
EO Tax Journal 2023-202
1 – Editor’s Notebook
2 – Applicant Assisting Students with School-Related Expenses Denied (c)(3) Status (Denial 202351013)
3 – Agenda for TEGE EO Council’s Spring Update
EO Tax Journal 2023-192
1 – Editor’s Notebook
2 – Rep. Foxx Announces Formal Investigation into Harvard, UPenn, and MIT
3 – Primer on Section 4942 Published
4 – Recent PLR Seems Problematic (PLR 202347002)
5 – But No Mercy for This Applicant (Denial 202347019)
EO Tax Journal 2023-181
1 – Employment Opportunity
2 – Editor’s Notebook
3 – Senators Vance and Braun Raise Concerns over IRS Targeting Conservative Groups
4 – Another LLC Denied (c)(3) Status (Denial 202344017)
EO Tax Journal 2023-179
1 – House Ways & Means Committee Announces Wednesday Hearing
2 – IRS Issues Proposed Section 4966 Regulations
3 – Editor’s Notebook
4 – Latest Exempt Organization Update from the IRS
5 – Recent IRS Written Determinations
6 – Applicant Housing and Caring for Rescued Cats Denied (c)(5) Status (Denial 202345010)