IRS priority guidance plan 2014-2015 - Exempt organization projects 

August 26:  The Treasury Department and IRS today released the IRS priority guidance plan for 2014-2015.

The 2014-2015 priority guidance plan [PDF 126 KB] is a list of projects that the tax authorities intend to work on during the 12-month period ending June 30, 2015, and includes projects relating to tax law issues in every conceivable area, ranging from consolidated returns to tax administration.

Exempt organization guidance projects

Projects under the heading “Exempt Organizations” include:

  • Revenue procedures updating grantor and contributor reliance criteria under sections 170 and 509
  • A revenue procedure to update Rev. Proc. 2011-33 for “EO Select Check”
  • Regulations under sections 501(a), 501(c)(3), and 508 to allow the Commissioner to adopt a streamlined application process that eligible organizations may use to apply for recognition of tax-exempt status under section 501(c)(3) (note that final and temporary regulations were published on July 2, 2014)
  • A revenue procedure setting forth procedures for issuing determination letters on exempt status under section 501(c)(3) to eligible organizations that submit Form 1023-EZ (note that Rev. Proc. 2014-40 was published on July 21, 2014, and released in advance on July 1, 2014)
  • Proposed regulations under section 501(c) relating to political campaign intervention
  • Final regulations on application for recognition of tax exemption as a qualified nonprofit health insurer under section 501(c)(29) as added by section 1322 of the Affordable Care Act (ACA) (note that temporary and proposed regulations were published on February 7, 2012)
  • Final regulations under sections 501(r) and 6033 on additional requirements for charitable hospitals as added by section 9007 of the ACA (note that proposed regulations were published on June 26, 2012, and April 5, 2013)
  • Additional guidance on section 509(a)(3) supporting organizations
  • Guidance under section 512 regarding methods of allocating expenses relating to dual-use facilities
  • Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners
  • Final regulations under sections 4942 and 4945 on reliance standards for making good faith determinations (note that proposed regulations were published on September 24, 2012)
  • Final regulations under section 4944 on program-related investments and other related guidance (note that proposed regulations were published on April 19, 2012)
  • Guidance regarding the excise taxes on donor advised funds and fund management
  • Guidance under section 6033 relating to the reporting of contributions
  • Final regulations under section 6104(c) (note that proposed regulations were published on March 15, 2011)
  • Final regulations under section 7611 relating to church tax inquiries and examinations (note that proposed regulations were published on August 5, 2009)

The IRS priority guidance plan also includes projects relating to regulations concerning the fractions rule under section 514(c)(9) and to final regulations under section 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations described in section 501(c)(9) (note that proposed regulations were published on February 6, 2014).

Projects relating to charitable contributions include: (1) final regulations under section 170 regarding charitable contributions (note that proposed regulations were published August 7, 2008), and (2) regulations under section 170(f)(8) regarding donor substantiation of charitable contributions.

Projects relating to tax-exempt bonds include a revenue procedure that will update Rev. Proc. 97-13 relating to the conditions under which a management contract does not result in private business use under section 141.

Other projects

Many other projects of interest to exempt organizations include, for example, projects involving employee benefits; a project involving regulations under section 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government; and a project related to the Supreme Court’s decision with respect to the Defense of Marriage Act.

For more information, contact:

Rick Speizman, Partner-in-Charge of KPMG's Washington National Tax Exempt Organizations Tax group

+1 (202) 533-3084

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