The 1996 Nonprofit Counsel Summaries
January 1996
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Congress Passes Tax Legislation, Which Is Vetoed; Negotiations For New Package Continue
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Quick Guide to the Act
February 1996
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Final Private Foundation Self-Dealing Regulations Issued
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Final Integrated Auxiliary Regulations Issued
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Other Church-Related Entities Exempted From Annual Filings [Rev. Proc. 96-10]
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IRS Updates Its Views on Museums and the UBIT [TAM 9550003]
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IRS Surveys Trade Association's Programs, Finds Unrelated Business [TAM 9550001]
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1996 Inflation Adjustments Provided by IRS [Rev. Proc. 95-53]
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Lobbying Disclosure Act: What It Means For Nonprofits
March 1996
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Hospitals' Insurance Funds Held Not Tax-Exempt Cooperatives [Florida Hospital Trust Fund v. Commissioner]
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A Look At the Intricacies of the Neighborhood Land Rule [PLR 9603019]
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Two Private Foundations Fully Sidestep Self-Dealing, One Partially [PLRs 9601048, 9604031, 9604006]
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PAC Grants to Foundation Held Not to be Personal Use of Funds [PLR 9603017]
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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]
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IRS Proposes Anti-Exemption Labor Organizations Regulation
April 1996
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Treasury, IRS List Guidance Priorities for 1996
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Tax Court Again Finds Affinity Card Revenue Nontaxable [Oregon State University Alumni Association, Inc. v. Commissioner]
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Lobbying Disclosure Act: An Update
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Management Services to Related Organization Held Exempt Function [TAM 9608003]
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IRS Approves Foundation's Loan and Grant to Research Partnership [PLR 9608039]
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Club Taxable on Timber Proceeds Because It Failed Reinvestment Rule [TAM 9608002]
May 1996
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Intermediate Sanctions Promptly Resurrected
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House Passes Health Bill, Which Includes New Exempt Organization
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IRS Rethinking Favorable Self-Dealing Ruling [PLR 9610032, withdrawing PLR 9540042]
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Insurance Activities Held to be Unrelated Business [TAM 9612003]
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Tax Treatment of Gifts to Foundation to Fulfill Its Pledge [PLR 9611047]
June 1996
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Intermediate Sanction Pass House
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IRS Rules Physician Compensation Not Private Inurement Nor Undue Benefit [PLR 9615030]
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Promotional Activities by Farm Bureau Federation Held Related Business [Ohio Farm Bureau Federation, Inc. v. Commissioner]
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No Self-Dealing When Foundation Assumes For-Profit Company's Program [PLR 9614003]
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IRS Finds Transfer of Assets From Estate Not Jeopardizing Investment [PLR 9614002]
July 1996
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Intermediate Sanctions: Where We Are
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IRS Issues Guidance as to Low-Income Housing Charities [Rev. Proc. 96-32]
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Free Rental Space Involving Exempt Organizations Held Related Business [PLR 9615045]
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Sales of Property Interests Held Not a Business, So No Taxable Income [PLR 9619068]
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Interorganizational Indebtedness Does Not Cause Unrelated Debt-Financed Property [PLR 9619077]
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IRS Proposes Audit Guidelines for Exempt Rural Electric Cooperatives [Ann. 96-24]
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No Need to File to Change Accounting Period Because of FASB Requirements [Notice 96-30]
August 1996
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Returns Processing to be Centralized in Ogden [Ann. 96-63]
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Appeals Court Affirms, Reverses, and Remands in Royalty Case [Sierra Club, Inc. v. Commissioner]
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In For-Profit Corporation Case, Executive's Compensation Held Unreasonable [Rapco, Inc. v. Commissioner]
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Museum Related to Taxable University Held Tax-Exempt [Bob Jones University Museum and Gallery, Inc. v. Commissioner]
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School Selling 8,500 Acres Over 25 Years Held Not Engaged in Unrelated Business [PLR 9619069]
September 1996
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Intermediate Sanctions Become Law
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New Law Brings Other Rules
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Account Collateralization Triggers Self-Dealing Taxes, Exemptio Loss [TAM 9627001]
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Exempt Membership Organization's Dues Held Unrelated Business Income [National League of Postmasters of the United States v. Commissioner]
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Insurer of Member Accounts Held an Exempt Business League [Credit Union Insurance Corporation v. United States]
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IRS Interprets Political Entity Funding Rules, Applies Political Organization Tax [TAM 9622002]
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Structural Tax Reform -- Impact on Tax-Exempt Organizations -- Part One
October 1996
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Small Business Tax Bill Includes Exempt Organization Provisions
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Insurance Reform Bill Includes Exempt Organization Provisions
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Group Insurance Plans Sponsorship Revenue Held Not Taxable as UBI [American Academy of Family Physicians v. United States]
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IRS Clarifies Pooled Fund Maintenance Requirements for Community Trusts [Rev. Rul. 96-38]
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Group Exemption Reporting Centralized
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Court Rejects Tax Exemption Sought by Entities Serving Hospitals and Schools [University Medical Resident Services, P.C. v. Commissioner]
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IRS Issues Intermediate Sanctions Filing Guidance [Notice 96-46]
November 1996
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IRS Find Candidate-Rating Forums to be Political Activity, Imposes Tax [TAM 9635003]
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IRS Finds Constructive Taxable Income in Mailing List Exchanges [TAM 9635001]
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Structural Tax Reform: Impact on Tax-Exempt Organizations -- Part Two
December 1996
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Election Aftermath: More Revocations, New Laws?
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Surplus Goods Purchase Program Ruled to Advance Charitable Functions [PLR 9641011]
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Partnership Investment Scheme Held to Not Adversely Affect Foundation's Exemption [PLR 9642051]
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Fund-Raising Regulation Report
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Certain Voter Registration Efforts Ruled Not Taxable Expenditures -- Part I [PLR 9640021]