The Nonprofit Counsel 1996 Summaries

January 1996

  • Congress Passes Tax Legislation, Which Is Vetoed; Negotiations For New Package Continue

  • Quick Guide to the Act


February 1996

  • Final Private Foundation Self-Dealing Regulations Issued

  • Final Integrated Auxiliary Regulations Issued

  • Other Church-Related Entities Exempted From Annual Filings [Rev. Proc. 96-10]

  • IRS Updates Its Views on Museums and the UBIT [TAM 9550003]

  • IRS Surveys Trade Association's Programs, Finds Unrelated Business [TAM 9550001]

  • 1996 Inflation Adjustments Provided by IRS [Rev. Proc. 95-53]

  • Lobbying Disclosure Act: What It Means For Nonprofits


March 1996

  • Hospitals' Insurance Funds Held Not Tax-Exempt Cooperatives [Florida Hospital Trust Fund v. Commissioner]

  • A Look At the Intricacies of the Neighborhood Land Rule [PLR 9603019]

  • Two Private Foundations Fully Sidestep Self-Dealing, One Partially [PLRs 9601048, 9604031, 9604006]

  • PAC Grants to Foundation Held Not to be Personal Use of Funds [PLR 9603017]

  • Organization Loses In Effort to Remain a Church by Procedural Maneuver [Gates Community Chapel of Rochester, Inc. d/b/a Freedom Village USA v. United States]

  • IRS Proposes Anti-Exemption Labor Organizations Regulation


April 1996

  • Treasury, IRS List Guidance Priorities for 1996

  • Tax Court Again Finds Affinity Card Revenue Nontaxable [Oregon State University Alumni Association, Inc. v. Commissioner]

  • Lobbying Disclosure Act: An Update

  • Management Services to Related Organization Held Exempt Function [TAM 9608003]

  • IRS Approves Foundation's Loan and Grant to Research Partnership [PLR 9608039]

  • Club Taxable on Timber Proceeds Because It Failed Reinvestment Rule [TAM 9608002]


May 1996

  • Intermediate Sanctions Promptly Resurrected

  • House Passes Health Bill, Which Includes New Exempt Organization

  • IRS Rethinking Favorable Self-Dealing Ruling [PLR 9610032, withdrawing PLR 9540042]

  • Insurance Activities Held to be Unrelated Business [TAM 9612003]

  • Tax Treatment of Gifts to Foundation to Fulfill Its Pledge [PLR 9611047]


June 1996

  • Intermediate Sanction Pass House

  • IRS Rules Physician Compensation Not Private Inurement Nor Undue Benefit [PLR 9615030]

  • Promotional Activities by Farm Bureau Federation Held Related Business [Ohio Farm Bureau Federation, Inc. v. Commissioner]

  • No Self-Dealing When Foundation Assumes For-Profit Company's Program [PLR 9614003]

  • IRS Finds Transfer of Assets From Estate Not Jeopardizing Investment [PLR 9614002]


July 1996

  • Intermediate Sanctions: Where We Are

  • IRS Issues Guidance as to Low-Income Housing Charities [Rev. Proc. 96-32]

  • Free Rental Space Involving Exempt Organizations Held Related Business [PLR 9615045]

  • Sales of Property Interests Held Not a Business, So No Taxable Income [PLR 9619068]

  • Interorganizational Indebtedness Does Not Cause Unrelated Debt-Financed Property [PLR 9619077]

  • IRS Proposes Audit Guidelines for Exempt Rural Electric Cooperatives [Ann. 96-24]

  • No Need to File to Change Accounting Period Because of FASB Requirements [Notice 96-30]


August 1996

  • Returns Processing to be Centralized in Ogden [Ann. 96-63]

  • Appeals Court Affirms, Reverses, and Remands in Royalty Case [Sierra Club, Inc. v. Commissioner]

  • In For-Profit Corporation Case, Executive's Compensation Held Unreasonable [Rapco, Inc. v. Commissioner]

  • Museum Related to Taxable University Held Tax-Exempt [Bob Jones University Museum and Gallery, Inc. v. Commissioner]

  • School Selling 8,500 Acres Over 25 Years Held Not Engaged in Unrelated Business [PLR 9619069]


September 1996

  • Intermediate Sanctions Become Law

  • New Law Brings Other Rules

  • Account Collateralization Triggers Self-Dealing Taxes, Exemptio Loss [TAM 9627001]

  • Exempt Membership Organization's Dues Held Unrelated Business Income [National League of Postmasters of the United States v. Commissioner]

  • Insurer of Member Accounts Held an Exempt Business League [Credit Union Insurance Corporation v. United States]

  • IRS Interprets Political Entity Funding Rules, Applies Political Organization Tax [TAM 9622002]

  • Structural Tax Reform -- Impact on Tax-Exempt Organizations -- Part One


October 1996

  • Small Business Tax Bill Includes Exempt Organization Provisions

  • Insurance Reform Bill Includes Exempt Organization Provisions

  • Group Insurance Plans Sponsorship Revenue Held Not Taxable as UBI [American Academy of Family Physicians v. United States]

  • IRS Clarifies Pooled Fund Maintenance Requirements for Community Trusts [Rev. Rul. 96-38]

  • Group Exemption Reporting Centralized

  • Court Rejects Tax Exemption Sought by Entities Serving Hospitals and Schools [University Medical Resident Services, P.C. v. Commissioner]

  • IRS Issues Intermediate Sanctions Filing Guidance [Notice 96-46]


November 1996

  • IRS Find Candidate-Rating Forums to be Political Activity, Imposes Tax [TAM 9635003]

  • IRS Finds Constructive Taxable Income in Mailing List Exchanges [TAM 9635001]

  • Structural Tax Reform: Impact on Tax-Exempt Organizations -- Part Two


December 1996

  • Election Aftermath: More Revocations, New Laws?

  • Surplus Goods Purchase Program Ruled to Advance Charitable Functions [PLR 9641011]

  • Partnership Investment Scheme Held to Not Adversely Affect Foundation's Exemption [PLR 9642051]

  • Fund-Raising Regulation Report

  • Certain Voter Registration Efforts Ruled Not Taxable Expenditures -- Part I [PLR 9640021]

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