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...

Bulk operations
Rated
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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31 Jan 2012 | Publications | National Publication | News story

The IRS has released Pub. 892, which describes how a tax-exempt organization can appeal the loss of its exempt status. 

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31 Jan 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 2012-7 indicates the applicable federal rate under section 7520 for February 2012 is 1.4%; unchanged from...

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30 Jan 2012 | Publications | National Publication | News story

The IRS has revised Pub. 523, Selling Your Home. Although not specific to charitable gift planning, this publication can be helpful to donors and their advisors in determining the basis and capital gain exclusion qualification rules applicable to personal...

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17 Jan 2012 | Letter Rulings | National Publication | News story

The IRS has ruled privately that a charitable trust that intended but failed to make an election to treat a contribution as having been paid in the prior year is granted an extension to make the election 

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In Email Chief Counsel Advice, the IRS has stated that so long as property qualifies for a charitable deduction, there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty. 

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The IRS has issued guidance with respect to issuing rulings and determination letters on private foundation status under § 509(a), operating foundation status under § 4942(j)(3), and exempt operating foundation status under § 4940(d)(2), of...

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The IRS has issued guidance that sets forth procedures for issuing determination letters and rulings on the exempt status of organizations under §§ 501 and 521 of the Internal Revenue Code. These procedures also apply to revocation or modification of...

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The Service has ruled privately that a private foundation's use of the proceeds of loans from a local financial institution to satisfy all or a portion of either the Initial set-aside amount and/or the additional set-aside amount for the purpose of constructing...

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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 2012-2 indicates the applicable federal rate under section 7520 for January 2012 is 1.4%; down 0.2% from...

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In keeping with its holiday season custom, the IRS has released its annual tips on year-end giving for taxpayers, which reviews several important tax law provisions that have taken effect in recent years..

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11 Dec 2011 | IRS Notices | National Publication | News story

The IRS has issued guidance for standard mileage rates for taxpayers to use in computing the deductible costs of operating an automobile for business, charitable, medical, or moving expense purposes for 2012. The rate for rendering gratuitous services to a...

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21 Nov 2011 | 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...

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14 Nov 2011 | Letter Rulings | National Publication | News story

The IRS has ruled privately that proposed sales of limited partnership interests by an executor back to the limited partnerships followed by the transfer of the cash sales proceeds to a testamentary charitable lead unitrust qualifies for the estate administration...

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Members of the American Bar Association's Estate and Gift Tax Committee of the Income and Transfer Tax Planning Group of the Trust and Estate Division of the Section of Real Property, Trust and Estate Law  have submitted comments, recommendations and...

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2 Nov 2011 | Comments | National Publication | News story

In a letter to Emily McMahon, Acting Assistant Secretary of Tax Policy, and writing on behalf of the Lettie Pate Whitehead Foundation, P. Russell Hardin has taken exception of Sen. Charles Grassley's recent characterization of supporting...

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In a new legal memorandum, the IRS has re-examined two prior memoranda and determined that "taxable income" for purposes of applying the 10% corporate limitation on charitable deductions is NOT adjusted for excess investment income from a real estate...

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The IRS has ruled privately that the debt of a third party oil and gas working interest owner will not constitute acquisition indebtedness to a private foundation under section 514 with respect to the foundation's net profits interest royalty that is...

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7520 Rates: February 1.4% January 1.4% December 1.6%

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Recent activity

Donated Funds and Tax Liens

March 7520 Rate Increases to 3.0%

IRS Releases Revised Pub. 526 - Charitable Contributions

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Webinar: Aligning Charitable Planning & Life Insurance

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Issuance of Units by University to CRTs Does Not Produce Unrelated Business Income

ACGA Asks IRS to Take Corrective Action on Notice

The IRS Reminds Tax-Exempt Organizations of All Sizes to File the Form 990 on Time to Preserve Their Tax Exempt Status

Grants to Foreign Charities are Qualifying Distributions