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
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.
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:
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In 2009 a limited liability company (LLC) in which Ps were members owned 355 acres of land (property) that it leased to
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
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.
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:
- The donations that Foundation makes pursuant to its matching donation programs will not constitute self-dealing under section 4941.
- The donations
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
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
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
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
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
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
Michael Kitces writes about donor advised funds (“DAF”), focusing on rules, strategies and tactics advisors might employ. His article begins as follows:
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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
Julie Chu, at Credit Suisse, writes about charitable planing for private equity and hedge fund principals. Her article begins as follows:
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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