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In determining if the sale of property held by a foundation produces unrelated business income, a determining factor is whether the property was held primarily for sale to customers in the ordinary course of a trade or business. Even though a foundation participated in the development of condomiums, the Service has ruled that a subsequent sale by the foundation of its interest will not produce UBI or adversely affect the foundation's 501(c)(3) exempt status.  MORE »

The Service has ruled in technical advice that loans from a corporation that is a disqualified person with respect to a private foundation to another business entity, a portion of which is also owned by the private foundation, is not an indirect act of self-dealing under section 4941.  MORE »

The Service has issued an advance copy of Rev. Proc. 2007-52 which sets forth the procedures for issuing determination letters and rulings on exempt status of organizations under sections 501 and 521. These procedures also apply to revocation and modification of determination letters or rulings, and provide guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under section 7428.  MORE »

Maintaining its consistency with prior rulings, the Service has ruled that early terminations of two charitable remainder unitrusts and division of trust assets between income recipients and charitable remaindmen will not result in the imposition of a termination tax under section 507(c) or be considered acts of self-dealing under section 4941.  MORE »

The U.S. Patent and Trademark Office has published a patent application in which the inventors claim a unique use of combinations of charitable remainder trusts, charitable lead trusts, gifts of remainder interests in real property, options, and life insurance to accomplish business tax planning objectives.  MORE »

The IRS website has new information tools ("Life Cycles") to help guide tax-exempt organizations through the federal tax rules that pertain to them. These tools are resources for certain organizations exempt under IRC sections 501(c)(3), (c)(4), (c)(5), and (c)(6). The website provides information about points of intersection between organizations and the IRS with explanatory information and links to forms an organization may need to file with the IRS.  MORE »

The Tax Section of the California State Bar has prepared a report that calls on Congress to develop legislation to restrict the issuance of tax patents, limit taxpayer and tax advisor liability for infringement, reduce the burden of proof for challenging tax patents or for defending patent infringement actions, and require the patent holder to license use of their inventions; calls on the USPTO to develop regulations which enhance access to and consideration of prior art by requiring all tax patent applications to be published, subject tax patents to challenge up to 12 months after being granted, and require disclosure to the IRS of all tax patent applications and all tax patent grants. Additionally, the report suggests the IRS should develop regulations which require disclosure to the IRS of all tax patent applications and all tax patent grants.  MORE »

In determining if the sale of property held by a foundation produces unrelated business income, a determining factor is whether the property was held primarily for sale to customers in the ordinary course of a trade or business. Even though a foundation participated in the development of condomiums, the Service has ruled that a subsequent sale by the foundation of its interest will not produce UBI or adversely affect the foundation's 501(c)(3) exempt status.  MORE »