The US Government Accountability Office, in a report made public in late January, issued its analysis of what it terms “for-profit college conversions,” in response to a request from four members of Congress. The GAO examined the extent to which the IRS and Department of Education responds to these conversions, particularly in relation to what it characterizes the “risk of improper benefit.” This report is titled “Higher Education: IRS and Education Could Better Address Risks Associated with Some For-Profit College Conversions” (GAO-21-89 (Dec. 2020)).
{"title":"GAO Issues (Rather Pointless) Report on Colleges' Tax Status Conversions","authors":"","doi":"10.1002/npc.30932","DOIUrl":"https://doi.org/10.1002/npc.30932","url":null,"abstract":"<p>The US Government Accountability Office, in a report made public in late January, issued its analysis of what it terms “for-profit college conversions,” in response to a request from four members of Congress. The GAO examined the extent to which the IRS and Department of Education responds to these conversions, particularly in relation to what it characterizes the “risk of improper benefit.” This report is titled “Higher Education: IRS and Education Could Better Address Risks Associated with Some For-Profit College Conversions” (GAO-21-89 (Dec. 2020)).</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 12","pages":"4-6"},"PeriodicalIF":0.0,"publicationDate":"2021-11-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"137701504","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Readers of this newsletter, which bears Bruce Hopkins' name, no doubt feel they know Bruce personally. His wit, wisdom, and personality shine through in his writings that kept readers up to date on the latest developments in nonprofit law. And, Bruce did more than provide a straightforward explanation of the matter at hand. What made Bruce unique is how adeptly he offered valuable insight and perspective about key developments, informed by some five decades of scholarship in the nonprofit field, and a willingness to speak frankly and criticize cases and rulings he found deficient in reasoning or result.
{"title":"In Memoriam: Bruce R. Hopkins","authors":"Celia Roady","doi":"10.1002/npc.30929","DOIUrl":"10.1002/npc.30929","url":null,"abstract":"<p>Readers of this newsletter, which bears Bruce Hopkins' name, no doubt feel they know Bruce personally. His wit, wisdom, and personality shine through in his writings that kept readers up to date on the latest developments in nonprofit law. And, Bruce did more than provide a straightforward explanation of the matter at hand. What made Bruce unique is how adeptly he offered valuable insight and perspective about key developments, informed by some five decades of scholarship in the nonprofit field, and a willingness to speak frankly and criticize cases and rulings he found deficient in reasoning or result.</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 12","pages":"1-2"},"PeriodicalIF":0.0,"publicationDate":"2021-11-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"91403844","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The Department of the Treasury and the IRS, on January 11, published final regulations in amplification of the law (IRC § 4960) imposing an excise tax on most types of tax-exempt organizations in connection with payment of remuneration of employees in excess of $1 million and excess parachute payments by these organizations (T.D. 9938). The Federal Register publication date for these regulations is January 19.
{"title":"Final Excess Compensation Regs Issued","authors":"","doi":"10.1002/npc.30936","DOIUrl":"https://doi.org/10.1002/npc.30936","url":null,"abstract":"<p>The Department of the Treasury and the IRS, on January 11, published final regulations in amplification of the law (IRC § 4960) imposing an excise tax on most types of tax-exempt organizations in connection with payment of remuneration of employees in excess of $1 million and excess parachute payments by these organizations (T.D. 9938). The <i>Federal Register</i> publication date for these regulations is January 19.</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 12","pages":"7-8"},"PeriodicalIF":0.0,"publicationDate":"2021-11-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"137701495","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The IRS issued a ruling holding that a private foundation's proposed grants to a supporting organization, formed for the benefit of a city, will constitute qualifying distributions and not taxable expenditures (Priv. Ltr. Rul. 202137007).
{"title":"Foundation's Grants to City's Supporting Organization Ruled Qualifying Distributions","authors":"","doi":"10.1002/npc.30921","DOIUrl":"10.1002/npc.30921","url":null,"abstract":"<p>The IRS issued a ruling holding that a private foundation's proposed grants to a supporting organization, formed for the benefit of a city, will constitute qualifying distributions and not taxable expenditures (Priv. Ltr. Rul. 202137007).</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"4-6"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"77519405","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The IRS ruled that a liquidation of a subsidiary, which is a tax-exempt entity, is not subject to the liquidation rules (of IRC § 337) because the type of transaction involved is not covered by the applicable tax regulations (Priv. Ltr. Rul. 202134013).
{"title":"Liquidation of Subsidiary Held Not Subject to Regulations","authors":"","doi":"10.1002/npc.30920","DOIUrl":"10.1002/npc.30920","url":null,"abstract":"<p>The IRS ruled that a liquidation of a subsidiary, which is a tax-exempt entity, is not subject to the liquidation rules (of IRC § 337) because the type of transaction involved is not covered by the applicable tax regulations (Priv. Ltr. Rul. 202134013).</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"4"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"75086564","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The IRS announced, on September 3, that—for an undetermined time—it will not issue rulings on whether an act of self-dealing occurs when a private foundation owns or receives an interest in a limited liability company or other entity that owns a promissory note issued by a disqualified person (Rev. Proc. 2021-40).
美国国税局于9月3日宣布，在一段不确定的时间内，当私人基金会拥有或获得有限责任公司或其他实体的权益时，是否存在自我交易行为(Rev. Proc. 2021-40)。
{"title":"IRS Issues No-Ruling Position on Self-Dealing and LLCs, Notes","authors":"","doi":"10.1002/npc.30918","DOIUrl":"10.1002/npc.30918","url":null,"abstract":"<p>The IRS announced, on September 3, that—for an undetermined time—it will not issue rulings on whether an act of self-dealing occurs when a private foundation owns or receives an interest in a limited liability company or other entity that owns a promissory note issued by a disqualified person (Rev. Proc. 2021-40).</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"3"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"80317593","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The Department of the Treasury and the IRS, on September 9, issued their 2021–2022 Priority Guidance Plan, containing 193 guidance projects that are priorities for allocating Treasury/IRS resources during the 12-month period from July 1, 2021 through June 30, 2022. Here are the relevant projects.
{"title":"Treasury, IRS Issue 2021–2022 Priority Guidance Plan","authors":"","doi":"10.1002/npc.30917","DOIUrl":"10.1002/npc.30917","url":null,"abstract":"<p>The Department of the Treasury and the IRS, on September 9, issued their 2021–2022 Priority Guidance Plan, containing 193 guidance projects that are priorities for allocating Treasury/IRS resources during the 12-month period from July 1, 2021 through June 30, 2022. Here are the relevant projects.</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"2-3"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"80654804","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The IRS declined to recognize a nonprofit organization as an educational organization, primarily because its program efforts are focused on enabling its members, all involved with a particular industry, to engage in networking (Priv. Ltr. Rul. 202135008).
{"title":"Networking Group Denied Recognition, Despite Some Educational Programs","authors":"","doi":"10.1002/npc.30922","DOIUrl":"10.1002/npc.30922","url":null,"abstract":"<p>The IRS declined to recognize a nonprofit organization as an educational organization, primarily because its program efforts are focused on enabling its members, all involved with a particular industry, to engage in networking (Priv. Ltr. Rul. 202135008).</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"6"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"91012890","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The House Committee on Ways and Means, on September 15, approved a proposed tax law revisions component of the Biden Administration's $3.5 trillion budget reconciliation legislation. The committee's bill includes, as expected, tax increases on for-profit corporations and the wealthy. This aspect of the proposed Build Back Better Act includes $2.1 trillion in tax hikes.
{"title":"Reconciliation Budget Bill, With Tax Proposals, Advances","authors":"","doi":"10.1002/npc.30916","DOIUrl":"10.1002/npc.30916","url":null,"abstract":"<p>The House Committee on Ways and Means, on September 15, approved a proposed tax law revisions component of the Biden Administration's $3.5 trillion budget reconciliation legislation. The committee's bill includes, as expected, tax increases on for-profit corporations and the wealthy. This aspect of the proposed Build Back Better Act includes $2.1 trillion in tax hikes.</p>","PeriodicalId":100204,"journal":{"name":"Bruce R. Hopkins' Nonprofit Counsel","volume":"38 11","pages":"1-2"},"PeriodicalIF":0.0,"publicationDate":"2021-10-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"81451321","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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