News & Analysis as of

Private Letter Rulings Charitable Organizations

Freeman Law

Another IRS Adverse Private Letter Ruling | Revocation of Tax-Exempt Status and Organizational and Operational Issues

Freeman Law on

In this ruling, a corporation’s I.R.C. § 501(c)(3) tax exempt status was under scrutiny. The corporation (“Company”) represented in its articles of incorporation and during its Form 1023 application process that it was...more

Freeman Law

Adverse Rulings from the IRS Exempt Organizations Division. How Can Your Organization Learn from Others’ Mistakes?

Freeman Law on

On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more

Miller Nash LLP

Today in Tax: Qualifying and Keeping a Religious Organization Tax-Exempt Requires a Bona-Fide Tax-Exempt Purpose

Miller Nash LLP on

Churches and religious organizations can both qualify as tax-exempt organizations described in Code Section 501(c)(3). In the case of churches, qualification can be achieved more simply than for a non-church. The allure of...more

Freeman Law

Skating on Thin Ice: IRS Does Not Recognize Organization’s 501(c)(3) Status

Freeman Law on

Various 501(c)(3) organizations may pursue charitable activities or operate to pursue altruistic purposes. However, what if such activities or purposes do not fall within the Internal Revenue Code’s requirements for...more

Polsinelli

IRS Attacks Impact Investing With Flawed Logic: A Critical Review of the IRS Argument

Polsinelli on

On October 9th, the Internal Revenue Service released Private Letter Ruling 202041009 (the “Ruling”), which, in what many in the nonprofit community would have expected to be a relatively straight-forward exemption approval...more

Polsinelli

IRS Ruling Takes Aim at Impact Investing

Polsinelli on

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more

Akerman LLP - Health Law Rx

Hospitals Take Heed: Gradual Evolution of the IRS’ Position on Tax Exemption

There has been much fanfare, but little discussion, among healthcare experts in the United States regarding the Internal Revenue Service recently published PLR 201731014. The Letter Ruling provides a good opportunity to...more

Patterson Belknap Webb & Tyler LLP

IRS to Update 1967 Revenue Ruling Relating to Change of Domicile

The Internal Revenue Service (the “IRS”) has announced plans to update Revenue Ruling 67-390, which requires an organization to “re-apply” for tax-exemption if it changes its corporate structure, including in situations...more

8 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide