Treasury

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Comments Requested on Guidance for Intellectual Property Donations

The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, has asked for comments regarding Notice 2005-41, which explains new rules governing charitable contributions of intellectual property made after June 3, 2004. The...

Service Approves CRAT Provision Permitting Purchase of Commercial Annuity Contract to Cover Annual Annuity Amount

The Service has ruled privately that a charitable remainder annuity trust can include a provision that grants the trustee the discretion to provide for the annuity payment to the income recipient by allocating a portion of the trust assets to purchase an annuity contract which...

SO Permitted to Specify Supported Organizations by Class or Purpose

The IRS has ruled privately that a supporting organization that amends its Articles of Incorporation to enable it to identify the organizations it will support by class or purpose rather than by name will not adversely affect its status as a Type 1 supporting...

 
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The IRS has released Issue 2012-9 of Exempt Organizations Update.

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14 May 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a family charitable trust does not meet the organizational test because it benefits named private individuals which is in direct contradiction to section 501(c)(3) of the Code. Further ruled, the organizing document fails to...

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30 Apr 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a state court's order to permit optional variable ascending annuity payments from a testamentary charitable lead annuity trust, commencing on the decedent's death and continuing for the 10-year annuity term, will satisfy...

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18 Apr 2012 | Revenue Rulings | National Publication | News story

For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 2012-13 indicates the applicable federal rate under section 7520 for May 2012 is 1.6%; up 0.2% from the...

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17 Apr 2012 | Regulations | National Publication | News story

The IRS has released final regulations under section 642(c) with regard to the Federal tax consequences of an ordering provision in a trust, a will, or a provision of local law that attempts to determine the tax character of the amounts paid to a charitable...

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12 Apr 2012 | IRS Notices | National Publication | News story | 1 comments

In response to IRS Notice 2012-25, which requests items for inclusion in the 2012-2013 Guidance Priority List, attorney Lawrence P. Katzenstein of of Thompson Coburn LLP has suggested three exceptions or clarifications be made to the qualified appraisal...

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The IRS has responded to an inquiry regarding to what extent donors, grantors, and contributors may rely on the listing of an organization in Publication 78, Cumulative List of Organizations or the IRS Business Master File (BMF) extract for purposes of...

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The IRS has clarified that, except in very limited situations,  a contribution of an easement subject to the condition the easement can be swapped is not deductible under section 170(h).

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27 Mar 2012 | Publications | National Publication | News story

The IRS has released Publication 598, Tax on Unrelated Business Income of Exempt Organizations, in which it describes which organizations are subject to the tax, return filing requirements, what an unrelated trade or business is, and how to...

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27 Mar 2012 | Treasury | National Publication | News story

The IRS has released its monthly issue of Exempt Organizations Update. In this issue: ...

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The Internal Revenue Service has launched a new online search tool, Exempt Organizations Select Check, to help users more easily find key information about tax-exempt organizations, such as federal tax status and filings.

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In 2010 the IRS issued Announcement 2010-19 in which it described procedures for certain charitable trusts that classified themselves as private foundations after August 16, 2007, to be reclassified as Type III supporting organizations. These procedures...

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22 Mar 2012 | Revenue Rulings | National Publication | News story

For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 2012-11 indicates the applicable federal rate under section 7520 for April 2012 is 1.4%; unchanged from...

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In a legal memorandum, the IRS has ruled that individual donors' gifts to an irrevocable trust are complete for gift tax purposes and therefore taxable gifts of a present interest. Further ruled, the beneficiaries' right to withdrawal (commonly referred to...

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The IRS has ruled privately that a private foundation's grants to individual medical researchers create a clinical information and biosample "biobank"  to enable the discovery of pathogens and pathogenic mechanisms in a specific disease will...

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5 Mar 2012 | Letter Rulings | National Publication | News story | 2 comments

The IRS has ruled privately that issuing units in an organization's endowment fund to a charitable remainder trust, the making of endowment fund payments to the trust, the receipt of endowment fund payments by the trust, and the holding or redemption...

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For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 2012-9 indicates the applicable federal rate under section 7520 for March 2012 is 1.4%; unchanged from the...

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13 Feb 2012 | Letter Rulings | National Publication | News story

The Service has ruled privately that a sale of real property by an estate from which a private foundation has an expectancy to a disqualified person in exchange for a promissory note is not a direct or indirect act of self-dealing because it qualifies as a...

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The IRS has ruled privately that scholarship awards made by a private foundation are excludable from the gross income of the recipients under section 117 of the Code. 

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The IRS has ruled privately that a private foundation's scholarship grants to artists are not taxable expenditures under section 4945. 

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7520 Rates: May 1.6% April 1.4% March 1.4%

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