By NEO Law Group
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 […]
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 […]
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 – […]
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 […]
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 […]
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 […]
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. […]
The following list of accomplishments of the Exempt Organizations division of the IRS (EO) in 2006 is excerpted (and slightly modified) from the IRS Letter to colleagues, members of the press and taxpayers dated as of November 7, 2006: Political Campaign Activity. EO responded to increased complaints about political intervention by 501(c)(3) organizations and dramatic […]
The following items are among the priorities of the IRS Exempt Organizations division (EO) for FY 2007: 1. New Projects: implementing new legislation gaming employment taxes telephone excise tax refund community foundations college and university unrelated business income tax (UBIT) 2. Form 990 redesign project. EO’s goal is to have a draft form and instructions […]
My Role “[T]he activities and affairs of the corporation shall be conducted and all corporate powers shall be exercised by or under the direction of the board. The board may delegate the management of the activities of the corporation to any person or persons, management company, or committee however composed, provided that the activities and […]