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Category: Philanthropy (page 1 of 4)

Rev. Proc. 2017-53: Guidelines Issued on Equivalency Determinations for Public Charity Status

In Rev. Proc. 2017-53, the IRS provides guidelines that tax practitioners may use to prepare written advice on which a domestic private foundation ordinarily may rely in making an equivalency determination that the grantee of a grant made for Code Sec. 170(c)(2)(B) purposes is a qualifying public charity.  The introduction … Continue reading

IRS Publication 4221-PF, Compliance Guide for 501(c)(3) Private Foundations Released

The IRS has released Publication 4221-PF (rev. Aug. 2014), “Compliance Guide for 501(c)(3) Private Foundations,” which explains the different types of private foundations, activities that could jeopardize a tax-exempt status, what federal information and tax returns private foundations must file, and required public disclosures, among other things.

Download Publication 4221-PF Continue reading

Rutkoske v. Commissioner: Tax Court Denies Farmer Conservation Easement Donation Deduction

in Rutkoske v. Commissioner, 149 T.C. No. 6 (Aug. 7, 2017), the Tax Court denied the conservation easement donation deduction to farmers.  The Tax Court Summary is as follows:

In 2009 a limited liability company (LLC) in which Ps were members owned 355 acres of land (property) that it leased to

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PLR 201731019: Private Foundation Established to Exhibit Art Loses Exempt Status Where Only One Exhibit Held

In PLR 201731019, a private foundation established to exhibit art lost its exempt status where it only held one art exhibit during its existence.

See PLR 201731019 by clicking here.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.… Continue reading

PLR 201729013 and 201729014: CRT – College Endowment Units In CRT Won’t Cause UBTI to College or Trust

In PLR 201729013, the IRS ruled that a contractual arrangement under which a college will issue units in its endowment fund to a CRT, make payments on the units, and be reimbursed to cover costs allocable to the management of the endowment or administration of the CRT, will not generate … Continue reading

Charitable IRA Initiative + Conrad Teitell Request Charitable IRA Be Included in Tax Reform

Tax Notes reports that, in response to a June letter by Senate Finance Committee Chair Orrin G. Hatch, R-Utah, requesting tax reform input, the Charitable IRA Initiative asked that the language of H.R. 1337 be included in the committee’s tax reform legislation.

See analysis of legislation prepared by Charitable IRA’s Continue reading

PLR 201725008: Ruling Re Matching Gifts by Private Foundation Matching Gifts of Employees of Corp That is Foundation’s Sole Contributor

The IRS made the following rulings with respect to donations made by a private foundation to match those made by employees of a corporation that is the foundation’s sole contributor:

  1. The donations that Foundation makes pursuant to its matching donation programs will not constitute self-dealing under section 4941.
  2. The donations
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Flawed Exempt Org Returns to be Rejected

Tax Analysts is reporting that the Service is likely to soon reject inaccurate or incomplete paper information returns filed by exempt organizations. It notes that “Maria Hooke, director (exempt organizations examinations), IRS Tax-Exempt and Government Entities Division, pointed out that while faulty returns submitted electronically are rejected upfront, the IRS works … Continue reading

Thune and Wyden Introduces Bill to Encourage Charitable Giving

U.S. Sens. John Thune, R-S.D., and Ron Wyden, D-Ore,. today introduced the Charities Helping Americans Regularly Throughout the Year (CHARITY) Act, a bipartisan bill that would encourage charitable giving and make it easier for foundations and other tax-exempt organizations to conduct their charitable missions.

Joined by Sens.  R-SD, Bob Casey, … Continue reading

Miller & Chevalier Requests Guidance on Charitable Contributions Under Section 170(e)(3)

Marc Gerson and George Hani, of Miller & Chevalier, have asked the Service to include on its 2017-2018 priority guidance plan guidance clarifying the treatment of acquisition costs for charitable contributions of inventory and other property under Section 170(e)(3), noting that this project is not only in accordance with, but … Continue reading

New York Society of CPAs Recommends Changes to Private Foundation Returns

In a comment letter addressed to Tamera Ripperda, Director of Exempt Organizations at the IRS, the New York Society of CPAs recommends that certain changes could be made to Form 990-PF, Return of Private Foundation (the Form) that would improve IRS oversight responsibilities, simplify and increase accuracy of form preparation … Continue reading

Court Upholds IRS Retroactive Revocation of Foundation’s Exempt Status Where Foundation Benefits One Family

In Educational Assistance Foundation for the Descendants of Hungarian Immigrants in The Performing Arts, Inc, the US District Court for the District of Columbia found that the Foundation in question operated in a manner that inured to the benefit of one family, precluding it from having tax-exempt status. Therefore, the … Continue reading

AICPA Offers Form 990 Recommendations to IRS

On June 17, 2015, The American Institute of CPAs (“AICPA”) offered more than 40 recommendations to the IRS for the Form 990, Return of Organization Exempt from Income Tax, and instructions.

The recommendations include the following:

  • adding thresholds throughout the instructions at the top of any schedule, part or line that
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Rules, Strategies, And Tactics When Using Donor-Advised Funds For Charitable Giving

Michael Kitces writes about donor advised funds (“DAF”), focusing on rules, strategies and tactics advisors might employ.  His article begins as follows:

The primary benefit of a donor-advised fund (DAF) is that it allows someone to donate assets for charity today – and receive a tax deduction now – even

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Donating Complex Assets

Julie Chu, at Credit Suisse, writes about charitable planing for private equity and hedge fund principals.  Her article begins as follows:

While estate planning for private equity and  hedge fund partners remains an important and widely addressed topic, the ascendancy of income tax management, in light of higher income

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