In a recent letter to IRS Commissioner Douglas Shulman, the American Hospital Association wrote that Schedule H of Form 990, which is used by nonprofit hospitals to report their community benefit activities, does not accurately reflect the activities of multi-hospital...
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The IRS has recently solicited public comments on Form 990, the informational return for tax-exempt organizations. The IRS uses Form 990 to determine whether exempt organizations continue to fulfill the qualifications and requirements for tax exemption and whether the filers...
In a recent letter to IRS Commissioner Douglas Shulman, members of the American Bar Association Section of Taxation proposed 17 examples of program-related investments (PRIs) by exempt organizations. These new examples supplement 19 other examples that the Section of Taxation...
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In a reversal of its prior position that medical residents are ineligible for the student exception from FICA taxes, the IRS announced that it will in fact honor the refund claims of residents, universities and hospitals made for tax periods...
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On March 2, 2010, the IRS and SEC announced that they would work together more closely in order to "monitor and regulate the municipal bond market and industry." The two agencies will focus on issues concerning tax-exempt bonds through a...
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The IRS is challenging compensation paid by the New York Stock Exchange to former chairman and CEO Richard A. Grasso on the basis that the compensation was unreasonable under Internal Revenue Code section 162. While serving as chair of NYSE's...
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The IRS recently solicited public comments on Treasury Regulation section 1.457-8, which concerns the eligible deferred compensation plans offered by state and local governments under Internal Revenue Code section 457. Comments are due by April 27, 2010. See also 2010...
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In a letter dated February 23, members of Clergy VOICE requested that IRS Commissioner Shulman investigate possible tax abuses by the C Street Center in Washington, DC. The C Street Center is classified as a church for federal tax purposes and...
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Executive Director of the Americans United for Separation of Church and State Barry W. Lynn recently asked the IRS to investigate Liberty University in Lynchburg, Virginia for a possible violation of a 501(c)(3) organization intervening in a partisan political campaign....
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In PLR 201007062, the IRS ruled that a private foundation organized as a trust could have an additional five years to dispose of certain excess business holdings, namely radio stations. The IRS found that radio stations are hard to sell,...
In PLR 201007063, the IRS ruled that contracts entered into by a university's supporting organization with charitable remainder trusts would not result in unrelated business taxable income (UBTI) to the supporting organization when the supporting organization was a beneficiary of...
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In PLR 201007071, the IRS revoked the tax-exempt status of a social club as described in Internal Revenue Code section 501(c)(7), because the social club did not keep adequate records to show that the club was operating for the exclusive benefit...
In PLR 201007076, the IRS retroactively revoked the tax-exempt status of a trust after finding that the trust was not operated exclusively for tax-exempt purposes and that its net earnings inured to the private benefit of the trustee, founders, board...
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In PLR 201007073, the IRS retroactively revoked the exempt status of an organization previously recognized as a 501(c)(3) organization because the organization failed to meet the reporting requirements under Internal Revenue Code sections 6001 and 6033. The organization had not...
In PLR 201007072, the IRS revoked the tax-exempt status of a 501(c)(3) organization because it was not operated exclusively for tax exempt purposes. Rather, the IRS found that the income of the organization inured to the personal benefits of the...
In PLR 201007068, the IRS revoked the tax-exempt status of an organization classified under Internal Revenue Code section 501(c)(3) because the organization failed to meet the reporting requirements of Code sections 6001 and 6033. These sections require that the books and records...
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In PLR 201007064, the IRS ruled that a private organization did not engage in self-dealing upon the transfer of assets to a separate private organization. The transfer of assets was due to a settlement agreement reached between certain members and...
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In PLR 201006032, the IRS revoked a prior letter ruling (PLR 200709065) that found a wholly-owned subsidiary of a nonprofit private foundation would be a functionally related business under Internal Revenue Code section 4942(j)(4). Posted by Jenny Robertson, Associate Editor,...
In PLR 201006033, the IRS ruled that scholarship awards made by a private foundation exempt from taxation would not be considered taxable expenditures under the Internal Revenue Code. The employer-related grant program was established to benefit the dependent children of...
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At the 46th annual Washington Nonprofit Legal and Tax Conference, former director of the IRS Exempt Organizations Division Marcus Owens offered advice on the IRS audit process, stating that the IRS has been "pretty aggressive" in its attempt to bypass...
Continue reading "Tax Notes Article: "IRS Aggressively Tries to Bypass Appeals""
