Startup charitable nonprofit organizations typically file with IRS for recognition of tax-exempt status under Section 501(c)(3) of the Internal Revenue Code shortly after formation. If an application for such recognition (Form 1023) is filed within 27 months of formation, and approved, the IRS recognizes tax-exempt status retroactively as of...
Earlier this year, the IRS released a private letter ruling (PLR 202119002) on a private foundation’s contemplated grants to three foreign organizations that will each regrant the applicable funds to secondary grantees in furtherance of the private foundation’s 501(c)(3) exempt purposes. While a PLR may not be relied on...
Georgetown Law held its 38th Annual Representing and Managing Tax-Exempt Organizations conference (virtual edition) last week. Among the sessions at the conference was a perennial favorite: Update on Key Current Developments presented by exempt organizations attorney Bruce Hopkins. Below are some of the many highlights from his presentation: IRS...
The IRS Tax Exempt & Government Entities Division (TE/GE) recently published its FY 2020 Accomplishments Letter. One segment of customers covered by TE/GE is Exempt Organizations (EO), which includes charities, private foundations, business leagues, labor unions, and veterans’ organizations. The other two segments of customers are Employee Plans and...
Here are some of the highlights from the virtual ABA Exempt Organizations Committee meeting held on January 28, 2021 as part of the ABA 2021 Midyear Tax Meeting. News from the IRS, Treasury, and the Hill Review of COVID-19 Related Legislation: Coronavirus Preparedness and Response Supplemental Appropriations Act –...
The Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (the “2021 COVID Relief Act”) was signed into law on December 27, 2020. The 2021 COVID Relief Act is a $900 billion part of the $1.4 trillion omnibus spending and appropriations bill that is viewed as the sequel to...
The following are some of the highlights from the session on Nonprofits in Distress at the 2020 Western Conference on Tax Exempt Organizations (WCTEO), presented by Erin Bradrick (NEO Law Group), Ofer Lion (Seyfarth Shaw), Tania Moyron (Dentons), and Stephanie Petit (Adler Colvin): Zone of Insolvency, Bankruptcy, and Debt Restructuring Under...
The following are some of the highlights from the session on Charitable Purpose in the 21st Century at the 2020 Western Conference on Tax Exempt Organizations (WCTEO): Historical context: Rev. Rul. 71-447: “All charitable trusts, educational or otherwise, are subject to the requirement that the purpose of the trust...
The joint Treasury and IRS 2020-2021 Priority Guidance Plan was published on November 17, 2020. The Plan includes a work list of projects for the 12-month period ending June 30, 2021. The following are some of the key provisions for exempt organizations: Tax Cuts and Jobs Act Regulations on...
The 24th Annual Western Conference on Tax-Exempt Organizations (WCTEO), my #1 go-to conference every year for the past 15 years, will be held virtually on Thursday, December 3, and Friday, December 4. The conference will be focused on the unique issues of these times and, in light of Zoom...