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501(c)(3)

California’s rule that it receive nonprofit’s Form 990 information held unconstitutional

California’s rule that it receive nonprofit’s Form 990 information held unconstitutional

Americans For Prosperity Foundation. v. Harris, (DC CA 4/21/2016) 117 AFTR 2d ¶ 2016-644 A U.S. district court has held that the state of California’s requirement that tax-exempt organizations submit IRS Form 990 Schedule B, which discloses names and contributions of significant donors, to the state is unconstitutional in its application to the organization that […]

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Court of Appeals – IRS can’t withhold names, etc. of tax-exempt status applicants from tea party groups

Court of Appeals – IRS can’t withhold names, etc. of tax-exempt status applicants from tea party groups

NorCal Tea Party Patriots, (CA 6 3/22/2016) 117 AFTR 2d ¶ 2016-525 The Court of Appeals for the Sixth Circuit has denied IRS’s petition for a writ of mandamus that would have permitted IRS to deny access by a Tea Party group to information in IRS’s files about the names, addresses and taxpayer identification numbers […]

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New procedures provided for revocation of exempt status; status modification no longer applies

New procedures provided for revocation of exempt status; status modification no longer applies

TEGE Memorandum: PATH Act – Impact on Revocations and Modifications of Exempt Status. To comply with the provision in the Protecting Americans from Tax Hikes (PATH) Act of 2015, a Tax-Exempt and Government Entities (TEGE) Division Memorandum has provided revised procedures under which all revocations of exempt status for organizations under Code Sec. 501(c) (regardless […]

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IRS looks at deductibility of business donations to charitable and other similar organizations

IRS looks at deductibility of business donations to charitable and other similar organizations

Chief Counsel Advice 201543013 Some civic-minded businesses advertise that they will give a certain percentage of their sales proceeds to organizations devoted to a particular cause, such as environmental conservation or eradicating hunger. A new Chief Counsel Advice (CCA) examines the deductibility of such donations made by a business to a variety of such organizations. […]

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Final regs allow private foundations to rely on qualified practitioners for charitable status

Final regs allow private foundations to rely on qualified practitioners for charitable status

T.D. 9740, 09/23/2015; Reg. § 53.4942(a)-3, Reg. § 53.4945-5 IRS has issued final regs on the standards for making a good faith determination that a foreign organization is a charitable organization that is not a private foundation, so that grants made to that foreign organization may be qualifying distributions and not taxable expenditures. Under the […]

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How to meet charitable hospital financial assistance provider list requirement

How to meet charitable hospital financial assistance provider list requirement

Notice 2015-46, 2015-28 IRB In a Notice, IRS has provided guidance for how charitable hospitals should comply with the requirement that, in order to maintain charitable organization status, they provide a list that specifies which providers, e.g., doctors, are covered by the hospital’s financial assistance policy (FAP) and which are not. Background. Code Sec. 501(r)(1) provides […]

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Court of Appeals: AIA Doesn’t Bar Org’s Lawsuit Alleging Heightened Review of its 501(C)(3) Application

Court of Appeals: AIA Doesn’t Bar Org’s Lawsuit Alleging Heightened Review of its 501(C)(3) Application

Z Street v. Koskinen, (CA Dist Col 06/19/2015) 115 AFTR 2d ¶2015-837 The Court of Appeals for the District of Columbia Circuit (DC Circuit) has affirmed a district court decision denying IRS’s motion to dismiss the complaint of a non-profit corporation alleging that its application for tax-exempt status under Code Sec. 501(c)(3), as well as […]

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Ninth Circuit Court of Appeals: State’s rule that it receive nonprofit’s return information isn’t preempted by Code

Ninth Circuit Court of Appeals: State’s rule that it receive nonprofit’s return information isn’t preempted by Code

Center for Competitive Politics v. Harris, (CA 9 5/1/2015) 115 AFTR 2d ¶ 2015-703 The Court of Appeals for the Ninth Circuit, affirming a district court decision, has ruled that the Code’s rules that limit disclosure of the names of persons who contribute to tax-exempt organizations do not preclude a state from requiring that such […]

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IRS provides correction & disclosure procedures so hospitals can avoid losing 501(c)(3) status

IRS provides correction & disclosure procedures so hospitals can avoid losing 501(c)(3) status

Rev Proc 2015-21, 2015-13 IRB In a Revenue Procedure, IRS has provided correction and disclosure procedures for hospital organizations to follow so that certain failures to meet the requirements of Code Sec. 501(r) would be excused for purposes of Code Sec. 501(r)(1) and Code Sec. 501(r)(2)(b), and the organization would not lose its Code Sec. […]

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IRS Provides Relief to Bondholders When Tax-Exempt Organization Loses Exempt Status

IRS Provides Relief to Bondholders When Tax-Exempt Organization Loses Exempt Status

Ann. 2015-02, 2015-03 IRB In an Announcement, IRS has provided a simplified process for issuers of qualified Code Sec. 501(c)(3) bonds to request a closing agreement in situations in which the borrower of the proceeds of the bonds had its exempt status revoked and then had it reinstated but not retroactively. If the steps of […]

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Court Dismisses Challenge to Church Reporting Exemption

Court Dismisses Challenge to Church Reporting Exemption

Freedom from Religion Foundation and Triangle FFRF v. Koskinen, (DC WI 12/17/2014) 114 AFTR 2d ¶ 2014-5548 A district court has dismissed a challenge by tax-exempt organizations to the exemption from reporting requirements for churches. The court determined that they lacked standing to sue because they never sought an exemption. Background. Under Code Sec. 6033(a)(1), most […]

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Court dismisses claim that IRS selectively enforces exempt org political campaign prohibition

Court dismisses claim that IRS selectively enforces exempt org political campaign prohibition

Freedom from Religion Foundation, Inc. v. Koskinen, (DC WI 08/01/2014) 114 AFTR 2d 2014-5141 A district court has dismissed a tax-exempt foundation’s claim that IRS selectively enforces the requirement that Code Sec. 501(c)(3) organizations not engage in political campaign activities by maintaining a policy of nonenforcement against churches and religious institutions. The foundation and IRS […]

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TAM upholds exempt status of organization that maintains community ice rink facilities

TAM upholds exempt status of organization that maintains community ice rink facilities

In a Technical Advice Memorandum (TAM), PLR 201344009, IRS determined that a not-for-profit organization that operates two recreational ice rink facilities and makes the rinks available to the general community for relatively low or zero cost is tax-exempt under Code Sec. 501(c)(3). Although the organization itself doesn’t directly educate children in hockey or figure skating, […]

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IRS memo sheds light on definition of political intervention by 501(c)(3) organizations

IRS memo sheds light on definition of political intervention by 501(c)(3) organizations

In an IRS Exempt Organizations internal memo, an IRS Director has set out activities that suggest the potential for political campaign intervention by applicants for Code Sec. 501(c)(3) status.   Click here for the text of the IRS memo entitled “Processing Guidelines for Section 501(c)(3) Applications Involving Potential Political Campaign Intervention.” Click here for a list […]

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Another Agency Goes IRS – How the FEC staff joined the political targeting of conservative groups

Another Agency Goes IRS – How the FEC staff joined the political targeting of conservative groups

As reported in the news of the WS Journal, “Another Agency Goes IRS – How the FEC staff joined the political targeting of conservative group,”one big question raised by IRS political targeting is whether Obama officials or their bureaucratic allies unleashed the power of the administrative state for partisan ends. Now evidence is emerging that […]

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Flurry of bills by House Republicans attempts to keep spotlight on IRS

Flurry of bills by House Republicans attempts to keep spotlight on IRS

As reported in the news, in an effort to keep the spotlight on the scrutiny of IRS, House Republicans passed the following bills by voice vote before leaving for the August recess: H.R.313, the “Government Spending Accountability Act of 2013,” a bill that would limit any government agency from spending more than $500,000 to support […]

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Liberal groups sue IRS to stop campaign spending by tax-exempts

Liberal groups sue IRS to stop campaign spending by tax-exempts

WASHINGTON, Aug 21 (Reuters) – Advocates for campaign finance transparency sued the Internal Revenue Service on Wednesday to force it to deny tax-exempt status to groups spending funds on political activities, launching a legal case that tax lawyers said faced long odds.  Ahead of the 2012 elections, liberal and conservative tax-exempt groups raised hundreds of […]

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Subpoena issued in response to slow pace of disclosure in IRS’s targeting of exempt orgs

Subpoena issued in response to slow pace of disclosure in IRS’s targeting of exempt orgs

Amid growing frustration from both House and Senate investigations, Acting IRS Commissioner Daniel Werfel has responded to charges that IRS has intentionally delayed responding to Congressional requests for information on IRS’s inappropriate targeting of the Tea Party and others in processing request for tax-exempt status. This dissatisfaction has now culminated in a subpoena from Darrell […]

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U.S. lawmaker tightens screws on IRS with Treasury subpoena

U.S. lawmaker tightens screws on IRS with Treasury subpoena

As reported in the news in Reuters, a senior Republican lawmaker on Friday issued a subpoena to U.S. Treasury Secretary Jack Lew seeking documents related to a nearly three-month old congressional probe of the Internal Revenue Service’s treatment of conservative political groups. In a move to keep the pressure on the Obama administration, Darrell Issa, […]

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National Taxpayer Advocate Identifies Priority Issues for Upcoming Year; Reports on Exempt Organization Review Concerns

National Taxpayer Advocate Identifies Priority Issues for Upcoming Year; Reports on Exempt Organization Review Concerns

IR-2013-63, National Taxpayer Advocate Nina E. Olson today (June 26) released her statutorily mandated mid-year report to Congress that identifies the priority issues the Taxpayer Advocate Service (TAS) will address during the upcoming fiscal year. The report expresses particular concern about the impact of budget cuts on the IRS’s ability to meet taxpayer needs, the […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney