White House Gulf Coast Philanthropic Briefing – September 13, 2010

Yesterday afternoon, I attended the first ever White House Gulf Coast Philanthropic Briefing hosted by the White House Initiative on Asian Americans and Pacific Islander (the "Initiative") in partnership with Asian Americans/Pacific Islanders in Philanthropy ("AAPIP") and the Corporation for National and Community Service ("CNCS").  The briefing was more of a convening and sharing of information […]

2009 Western Conference on Tax-Exempt Organizations – Day Two

Day Two of the WCTEO began with EO attorney Bruce Hopkins delivering his always informative and entertaining program on new developments over the past year, focusing particularly on private letter rulings (PLRs).  Here are some of the notable PLRs: Denying recognition of exemption under 501(c)(3) because of operation in substantially commercial manner:  200944053 Denying recognition of […]

Private Letter Rulings and the L3C

2009 is an interesting year for the low-profit limited liability (L3C) concept because it presents the first test of an L3C’s ability to operate under current federal law and IRS regulations. One concern raised is the process by which private foundations will make program-related investments (PRIs) to this new legal entity. A PRI is an […]

2009 Georgetown Exempt Organizations Conference – Day Two

Here are my tweets from day two of the Georgetown Representing & Managing Tax-Exempt Organizations Conference: Nonprofit lawyers James Hansen, Peter Holiat (IRS), and Virginia Richardson (IRS) speak on current UBIT issues at Georgetown EO Conf 2008 PLR: Community foundation sells unique grantmaking consulting svcs (related income) and admin svcs (unrelated) to grantmaking orgs 2008 […]

2009 Georgetown Exempt Organizations Conference – Day One

I tweeted day one of the 2009 Georgetown Representing & Managing Tax-Exempt Organizations Conference today. The absence of wireless access in the Hyatt conference rooms prevented live tweeting, but I posted the following tweets during breaks and in the evening: IRS Director, Exempt Organizations, Lois Lerner, noted an increase in EO applications this year – […]

IRS Exempt Organizations Division 2009 Work Plan

Improved Service to Achieve Voluntary Compliance Preparing and Helping to File the Form 990 (speeches, workshops, tax forums) Form 990-N (e-Postcard) Guidance (including proposed regulations on (i) new requirements for supporting organizations, and (ii) excise taxes on donor advised funds; and final regulations on excise taxes on prohibited tax shelter transactions and related disclosure requirements)  Exempt […]

Highlights of the 2008 Western Conference on Tax Exempt Organizations (Part Two)

More Highlights of the 2008 Western Conference on Tax Exempt Organizations: Games and Gaming, William C. Choi and James Cordi See California AG site on Raffles here Million Dollar Home Raffles (think about UBIT, public support, withholding, 90% rule, and internet usage issues) California Compliance, James Cordi and Dwayne M. Horii California Property Tax Exemption […]

Dissolution

The well-known saying, “Honesty is the best policy,” rings especially true for nonprofit organizations and the topic of dissolution. Although a tough decision and perhaps one that many will want to avoid, it is important for organizations to (a) acknowledge in a candid and timely manner when they’ve reach the point where continued operation is […]

Final 501(c)(3) and 4958 Regulations Released – Part I

The IRS released final regulations that clarify (i) the substantive requirements for tax exemption under section 501(c)(3) of the Internal Revenue Code; and (ii) the relationship between the substantive requirements for tax exemption under section 501(c)(3) and the imposition of section 4958 excise taxes on excess benefit transactions.  The regulations became effective March 28, 2008. […]