Focus on IRS and Treasury

Focus on IRS and Treasury Transcripts (Other)

EO Tax Journal 2010-48

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Today I have a transcript of an interesting governance discussion that should be of interest to everyone. Lois Lerner represented the IRS, and I was good — I didn’t ask her where the PACI report is (now one year late) or the EO workplan (six months late).

Fred Goldberg mentioned Announcement 2010-9 and I have reprinted it after the transcript. In addition to Fred, a number of practitioners have said Announcement 2010-9 will affect exempt organizations as well as for-profit corporations. Suzie McDowell mentioned information available from Eve Borenstein, and I have added how to obtain this information after the transcript.

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

EO Tax Journal 2010-46

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A bit of this and that today. I expect to have a transcript of an interesting governance discussion that occurred last week featuring Fred Goldberg, Lois Lerner, and Suzanne McDowell if — and this is a big if — my transcriber — a big fan of Kentucky — can recover from Kentucky’s loss to West Virginia in the NCAA Men’s Basketball Tournament.

1 – Ten Tips for Deducting Charitable Contributions

2 – Six Important Facts about Tax-Exempt Organizations

3 – Grassley on New Hospital Provisions

4 – Providing Administrative Services Will Not Constitute Unrelated Trade or Business (PLR 201012052)

5 – Transfer of LLC Units to PF Will Not Constitute Self-Dealing or Recognition of Gain to Donors (PLR 201012050)

Focus on IRS and Treasury

EO Tax Journal 2010-41

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1 – Coming Attractions

2 – AHA Concerned About Schedule H “Flaws”
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1 – Coming Attractions

27th Annual “Representing & Managing Tax-Exempt Organizations” Conference
April 22-23, 2010, Washington, D.C.

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

EO Tax Journal 2010-40

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My bookshelf

I kind of skimmed Sarah Palin’s book, Going Rogue, so I shouldn’t comment on what I didn’t really read. From another source, I learned that Palin has ancestors from County Roscommon in Ireland. Well, my mother’s family goes back to County Roscommon, too. Who knows, I may be a distant cousin. If Palin becomes President, someone remind her of that. I’d like to be an ambassador, preferably to a country where the living is good and the toasts never end.

Editor's Notebook Focus on IRS and Treasury

EO Tax Journal 2010-38

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ABA’s Recommendations for More PRI Examples

I’m reprinting below the recent comments of the ABA’s Tax Section. I’ve also reprinted my prior comments on the ABA’s earlier recommendations. I continue to have concerns that we will have an “anything goes” situation with private foundations and their PRIs. Who determines a below-market rate of interest and how? Who determines that conventional sources of financing are not available and how? Who determines that no for-profit investors are interested and how? Should equity investments and “equity kickers” be allowed in any instances? Doesn’t the potential for high profits attract venture capital? Should foundations become owners of the ventures they are financing?

Focus on IRS and Treasury

EO Tax Journal 2010-26

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Marc Owens, in a recent letter, reprinted below, is protesting a denial by the IRS Office of Appeals of his request for technical advice. Hey, the IRS already did its technical advice for the year (TAM 201005061). Two TAMs in one year? That’s asking a lot.

Focus on IRS and Treasury

EO Tax Journal 2010-24

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For those of you who live and die the Form 990, you probably spent the weekend studying the revised 2009 Form 990, schedules and instructions, posted last week by the IRS. For the rest of us, it’s more a matter of what we care about. What struck my fancy were two statements in the IRS announcement of significant changes, reprinted in its entirety below.

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

EO Tax Journal 201-23

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Monday’s email update on excerpts from Sarah Hall Ingram’s Feb. 5 remarks has drawn comments.

Former EO Branch Chief Connie Rosenberg had this to say:

“I think Sarah’s answer to the question about Service failure to publish formal guidance was quite truthful, if you parse it out carefully. What she said, in effect, was: we can’t figure out how to get publications out because we, collectively, can’t figure out how to stop tripping over each other. As Winston Churchill once said (whenever I’m not sure who said something, I always cite Churchill, and I’m usually right): the way to begin is to begin. The way to stop tripping over each other is to stop tripping over each other. Set up a formal procedure for initiating and clearing a publication; follow that procedure; establish due dates for movement at each stage of the process; appoint a high-ranking management official to monitor the due dates and insist that they be met, and provide consequences for the bureaucrat who fails to meet them; be prepared to deal with the consequences of actually making a decision. Those things are the jobs of management. It ain’t rocket science now, any more than it was 25 years ago, but it does take some guts.”

Focus on IRS and Treasury Transcripts (ABA EO Committee)

EO Tax Journal 2010-21

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The use of gmail seems to be working. I’ll continue to use it this week and, if successful, get back to replacing the lost emails caused by AOL. The next issue of the print issue of theEO Tax Journal will have all the email updates, so that may be the answer for those who receive it. I’ll keep you posted as we try to get past this latest snafu.

Focus on Congress Focus on IRS and Treasury

EO Tax Journal 2010-16

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1 – EO Revenue Procedures Updated

The annual updating of the basic EO revenue procedures has taken place with few changes.

Rev. Proc. 2010-4, on TE/GE letter ruling requests, has mostly minor revisions. An additional circumstance under which EO Technical will not issue letter rulings is added as section 6.18.

Focus on IRS and Treasury

EO Tax Journal 2010-13

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A hearing on the proposed section 7611 regulations was held yesterday, featuring three commenters. For the proposed regulations, see EOTJ, vol. 14, no. 4, p. 158. For written comments on the proposed regulations, see EOTJ, vol. 14, no. 6, pp. 145-171. What follows is the prepared testimony of Marc Owens for the hearing. Joining Owens in commenting were Pennsylvania attorney David Epstein and Erik Stanley, senior legal counsel, Alliance Defense Fund.

Editor's Notebook Focus on IRS and Treasury

EO Tax Journal 2010-12

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1 – Leave Our Guy Alone

In Monday’s email update on The Chronicle of Higher Education’s annual survey of salaries of leaders of public universities, it was noted that “As in 2008, E. Gordon Gee, president of Ohio State University, topped the Chronicle’sranking for 2009, with an annual compensation package valued at nearly $1.6 million.”

Current & Quotable Focus on IRS and Treasury

EO Tax Journal 2010-5

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1 – Charlotte Observer: “For Too Many Nonprofits, Charity Starts at the Top”

What a reporter for the Charlotte Observer did in the Carolinas should be done by the IRS nationwide. And if the IRS is not applying section 4958 to the cases identified in the article, reprinted infra, when will it ever?