Tax Notes has published an article by Nicola F. Toubia of Fuentes Toubia PLLC. The article publishes comments drafted to the IRS by Toubia in response to proposed regulations on qualification requirements of Type III supporting organizations "operated in connection with one or more supported organizations." Toubia writes on behalf of The Sealy & Smith Foundation, a Type III supporting organization under Internal Revenue Code section 509(a)(3). The comments suggest changes to the proposed rule, including clarifications on the definition of "functionally integrated," modifications to the government entities exception, and adopting a "historical supporting organizations" exception.
See Nicola F. Toubia, "Firm Seeks Changes to Proposed Regs on Type III Supporting Organizations," 2010 TNT 4-17, December 18, 2009
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal
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