1 – Editor’s Notebook
2 – In the News
3 – Organization Providing Consulting Services Denied (c)(3) Status (Denial 202335015)
PLRs, TAMs, and Denial Letters
EO Tax Journal 2023-138
1 – Employment Opportunity
2 – Editor’s Notebook
3 – Last Week’s EO Division Work Product
EO Tax Journal 2023-136
1 – Editor’s Notebook
2 – Current & Quotable
3 – In the News
4 – Article of Interest
5 – Income of Organization Enhancing Economic Development Excluded from Gross Income under Section 115(1) (PLR 202334002)
EO Tax Journal 2023-133
1 – The EOTJ Mailbag
2 – In the News
3 – Editor’s Notebook
4 – Homeowners Association Denied (c)(4) Exempt Status (Denial 202333005)
EO Tax Journal 2023-132
1 – The EOTJ Mailbag
2 – Editor’s Notebook
3 – Summary of Opinion in Huntsman Case
4 – Excerpts from Huntsman Case re Ecclesiastical Abstention Doctrine
5 – IRS Advises on Whether Federal Credit Unions May Claim the Employee Retention Credit (CCA 202333001)
EO Tax Journal 2023-130
1 – Editor’s Notebook
2 – In the News
3 – Summary of Last Week’s EO Determinations
4 – Applicant Engaged in Commercial Activities with Evidence of Inurement or Private Benefit Denied (c)(3) Status (Denial 202332014)
EO Tax Journal 2023-123
1 – Editor’s Notebook
2 – In the News
3 – Applicant Providing Pharmaceutical Products and Services Denied (c)(4) Status (Denial 202331004)
EO Tax Journal 2023-112
1 – Editor’s Notebook
2 – In the News
3 – Foundation Granted Five-Year Extension for Disposing of Its Excess Business Holdings under Section 4943(c)(7) (PLR 202328018)
4 – Consolidation of Operations of Two Foundations Approved (PLR 202328005)
EO Tax Journal 2023-105
1 – Editor’s Notebook
2 – In the News
3 – Article of Interest
4 – IRS Rules (c)(3) Organization’s School Food Authority Meal Program Furthers an Exempt Purpose Described in Section 501(c)(3) (PLR 202326008)
5 – Income of Trust Established to Fund Health and Welfare Benefits for Eligible Retirees of Association Whose Income Is Excludible under Section 115(1) Is Also Excludible under Section 115(1) (PLR 202326003)
EO Tax Journal 2023-95
1 – In the News
2 – Editor’s Notebook
3 – Applicant Denied in Part for Failure to Meet the Organizational Requirements for an LLC Outlined in Notice 2021-56 (Denial 202323011)
4 – ABA Submits PGP Recommendations
EO Tax Journal 2023-93
1 – Employment Opportunity
2 – Editor’s Notebook
3 – IRS Explanation of New GLAM
4 – Generic Legal Advice Memorandum on NIL Collectives (GLAM 2023-004)
EO Tax Journal 2023-78
1 – Editor’s Notebook
2 – Applicant Providing Members with Health Care Sharing Services Denied (c)(3) Status (Denial 202318021)
3 – Improving Nationwide Access to IRS Appeals; Public Input Wanted (IR-2023-101)
EO Tax Journal 2023-68
1 – Editor’s Notebook
2 – TEGE Exempt Organizations Council to Present EO Update on June 9, 2023
3 – IRS Seeks Membership Nominations for the 2024 Internal Revenue Service Advisory Council
4 – Applicant Seeking to Create and Maintaining a Political Party in a Foreign Country Denied (c)(3) Status (Denial 202316011)
EO Tax Journal 2023-62
1 – Editor’s Notebook
2 – Employment Opportunity
3 – In the News
4 – IRS Written Determinations
5 – ABA’s EO Committee to Meet on May 5
6 – Climate Change Update (Part 1)
EO Tax Journal 2023-39
1 – Attorney Employment Opportunity
2 – Editor’s Notebook
3 – Latest EO Division Work Product
4 – Conservation Easements Update: Cert. Denial; Hearing on Proposed Regs; New Articles
5 – Applicant Engaged in Training Dogs and Dog Owners Denied (c)(3) Status (Denial 202309017)
EO Tax Journal 2023-33
1 – Editor’s Notebook
2 – Critics Say Many Virginia Hospitals Offer Little Charity Care
3 – Applicant Operating a Cooperative Organization Using a Bartering Exchange for Benefit of Members Denied (c)(3) Status (Denial 202308012)
EO Tax Journal 2023-29
1 – Editor’s Notebook
2 – The EOTJ Mailbag
3 – Employment Notice
4 – Applicant Engaged in Religious Matchmaking Denied (c)(3) Status (Denial 202307007)
EO Tax Journal 2023-21
1 – Editor’s Notebook
2 – Latest Public Release of EO Written Determinations
3 – IRS Rules Grant from Dissolving Hospital Qualifies as an Unusual Grant for Exclusion from Public Support Calculation (Letter 202305020)
4 – Philanthropy Roundtable Ranks the States
EO Tax Journal 2023-17
1 – Editor’s Notebook
2 – IRS’s Latest EO Update Released
3 – EO Determinations Updates and Clarifies Proposed Adverse Case Processing
4 – Applicant Conducting an Annual Family Reunion and Awarding Scholarships to Family Members Denied (c)(3) Exemption (Denial 202304014)
EO Tax Journal 2022-214
1 – Editor’s Notebook
2 – Crypto in the News
3 – NY Attorney General James Releases Annual ‘Pennies for Charity’ Report
4 – Alaska’s Sandy Deja Points Out Urgent Need to Change Question 2 of Part IV of Form 1023-EZ
5 – Organization Engaged in Political Activities Held Not to Qualify under Section 501(c)(4) (Revocation 202247012)
EO Tax Journal 2022-206
1 – Editor’s Notebook
2 – EO Programs This Week
3 – Upcoming EO Program
4 – Applicant Claiming that It Is a Social Welfare Organization under Section 501(c)(4) Denied Exempt Status (Denial 202226014)
EO Tax Journal 2022-199
1 – Editor’s Notebook
2 – Articles of Interest
3 – IRS Memorandum 202243008: Interest that Accrues during Closed Years Is Included in the Loan Balance to Compute the Amount Involved for the Deemed Acts of Self-Dealing in Open Years
4 – IRS News Release: 2023 PTIN Renewal Period Underway for Tax Professionals
EO Tax Journal 2022-189
1 – Editor’s Notebook
2 – In the News
3 – Tax-Exempt Organizations, Charities and Nonprofits Update (Part 1)
4 – Taxpayer’s Proposal to Expand its Eligible Membership to Include All Former Employees Ruled Permissible under Section 501(c)(9) (PLR 202236004)
EO Tax Journal 2022-174
1 – Editor’s Notebook
2 – Section 107 in the News
3 – News from Latest IRS EO Update
4 – Applicant Conducting Annual Community Automotive Event Denied (c)(3) Status But Retains (c)(4) Status (Denial 202237011)