Council on Foundations Vice President and General Counsel Janne Gallagher provided an update on supporting organizations after the Pension Protection Act of 2006 (the "PPA"). As a result of the PPA, private foundations and sponsoring organizations of donor-advised funds must determine: (1) whether a charity to which they are...
CoF Advanced Legal Seminar – Tax-Shelter Transactions
Chair of the Exempt Organizations Committee of the ABA Section of Taxation LaVerne Woods discussed the topic of charities and tax shelters. Her presentation began with a quote from IRS Commissioner Mark W. Everson at a Senate Finance Committee Hearing in 2004: "I cannot overstate the seriousness of the...
CoF Advanced Legal Seminar – Low-profit Limited Liability Company (L3C)
At the Council on Foundation Conference, former director of the Exempt Organizations division of the IRS Marcus Owens discussed the concept of a new form of legal entity that might be an appropriate vehicle (1) for social enterprises, and (2) to receive program-related investments – the low-profit limited liability...
CoF Advanced Legal Seminar – Program-Related Investments
The Advanced Legal Seminar given at the Council on Foundations Conference featured Lisa Johnsen of Kirkpatrick & Lockhart Preston Gates Ellis; Marcus Owens of Caplin & Drysdale and former head of the Exempt Organizations division of the IRS; LaVerne Woods of Davis Wright & Tremaine and Chair of the...
Council on Foundations 2007 Annual Conference
The Council on Foundations, together with Philanthropy Northwest, kicked off its 2007 Annual Conference in Seattle on April 29. The theme of the Conference: Philanthropy and the Challenges of Our Time: Making a Difference at Home and Around the Globe. The Conference focused on four intractable challenges: poverty, public...
Melinda Gates Speaks at Council on Foundations Annual Conference
Melinda Gates, co-chair of the Bill & Melinda Gates Foundation, delivered the morning plenary address at the 2007 Annual Conference of the Council on Foundations and Philanthropy Northwest. Gates opened with an anecdote about her then three-year old child struggling to tie her shoes saying "it’s difficult … I...
IRS EO Executive Compensation Report
The IRS released Parts I and II of its Report on Exempt Organizations Executive Compensation Compliance Project earlier this month. Part I involved compliance check letters sent to 1,223 organizations. Part II involved examinations of 782 organizations. Among the findings of the Report: Significant reporting issues exist. Over 30%...
Donor Restrictions Seminar – March 1, 2007
On March 1, The San Francisco Foundation presented, as part of its Professional Advisor Seminar Series, Donor Restrictions – What Will Your Clients Think of Next, featuring Erik Dryburgh, a highly respected attorney with Silk, Adler & Colvin. Erik focused both on donor issues and charity issues with respect...

Group Exemption
UPDATE (6/16/20): IRS Notice 2020-36 This notice contains a proposed revenue procedure that sets forth updated procedures under which recognition of exemption from federal income tax for organizations described in ยง 501(c) of the Internal Revenue Code (Code) may be obtained on a group basis for subordinate organizations affiliated...
Free Online IRS Training
The IRS is now offering interactive online workshops designed for small- and mid-sized charitable organizations on the following topics: Tax-Exempt Status – How can you keep your 501(c)(3) exempt? Unrelated Business Income – Does your organization generate taxable income? Employment Issues – How should you treat your workers for...