Tuesday May 7, 2024

Chapter 9 -- Tax References

CHARITABLE ORGANIZATIONS


Qualifying as an Exempt Organization


Notice 2011-44 Applying for Reinstatement of Tax-Exempt Status

Notice 2011-43 Transitional Relief for Certain Small Organizations that have Lost their Tax-Exempt Status Because they Failed to File a Required Annual Electronic Notice

Rev. Rul. 2007-41 Election Activities

Rev. Rul. 83-157 Exempt Status of a Hospital

Rev. Rul. 69-545 Qualifying for Exemption from Federal Income Tax Under Sec. 501(c)(3)

Rev. Rul. 59-129 Salvation Army is a Public Charity

Rev. Rul. 56-185 Criteria for a Hospital to be Classified as a Charitable Organization

Use of Funds


Notice 2008-49 Public Inspection of Form 990-T

Notice 2000-24 Charitable Split Dollar Excise Tax


Unrelated Business Income Tax


Notice 2018-100 The Service granted penalty relief for nonprofits that failed to pay estimated taxes on 2018 parking UBIT.

Notice 2018-99 The Service explained the general rules for determining unrelated business income tax for nonprofit employee parking.


CHARITABLE REMAINDER TRUSTS


Creation-Drafting Provisions and Sample Language


Rev. Rul. 88-81 Sample Language for Charitable Remainder Trusts

Rev. Rul. 82-165 Charitable Remainder Trusts-Sample Provisions

Rev. Rul. 73-610 Charitable Remainder Trusts- Qualifications

Rev. Rul. 72-395 Charitable Remainder Trusts- Mandatory and Optional Provisions

Funding


Bonds
Rev. Rul. 58-2 U.S. Savings Bonds in a Charitable Trust

Life Insurance
Rev. Rul. 84-179 Incidents of Ownership in an Insurance Funded Unitrust

Stock
Rev. Rul. 78-197 Stock Redemption from a Trust and the Pre-Arranged Sale Rules

Payout


Rev. Rul. 92-57 Computing Deferred Payments from a Unitrust

Reformation and Termination


Rev. Rul. 2008-41 IRS Rules on Split-Up Split Unitrusts

Notice 2008-99 IRS Requires Charities to Report CRT Sales

Notice 99-31 FLIP Deadline Extended to June 30, 2000

Rev. Rul. 86-60 Reformed Trusts

Rev. Rul. 77-374 Reformed Trusts

Rev. Rul. 77-285 Charitable Remainder Trusts- Power to Remove the Trustee

Special Needs Trusts


Rev. Rul. 2002-20 Unitrust Payments to a Special Needs Trust

Testamentary Unitrusts


Rev. Rul. 82-128 Federal and State Estate Taxes are not Payable from a Charitable Remainder Trust

Rev. Rul. 80-123 Testamentary Unitrust Language


DONOR ADVISED FUNDS


Notice 2017-73 Request for Comments on Application of Excise Taxes With Respect to Donor Advised Funds in Certain Situations



GIFT ANNUITIES AND BARGAIN SALES


Rev. Rul. 81-163 Bargain Sales

Rev. Rul. 80-281 Gift Tax Deductions from Gift Annuities

Rev. Rul. 62-137 Valuing Charitable Gift Annuities


OUTRIGHT GIFTS


Delivery/Timing of Gift


Notice 2004-83 Private Delivery Services Qualify for "Mailbox Rule"

Gifts on a Donor's Credit Card


Rev. Rul. 78-38 Charitable Gifts via Credit Card

Foreign Charities and US Charity Affiliates


Notice 2011-32 Japanese Tsunami Zone is Qualified Disaster under Sec. 139

Rev. Rul. 74-523 Gifts to Foreign Charities

Insurance


Notice 2007-24 Insurance Reporting Requirements

Inventory


Rev. Rul. 80-329 Gifts of Inventory

Rev. Rul. 79-419 Deduction for Inventory Gifts

Partial Interests


Rev. Rul. 87-37 Gifts of Partial Interests in Real Property

Patents


Rev. Rul. 2003-28 Gifts of Patents

Rev. Rul. 58-260 Deductibility of an Undivided Present Interest Gift of a Patent

Payroll Gifts


Notice 2006-110 Requirements for Payroll Deductions

Real Estate


Rev. Rul. 55-410 Contributions or Gifts by Individuals of Appreciated/Depreciated Property

Rev. Rul. 55-157 Installment Basis from a Sale of Real Property to Charity

Notice 2017-10 Listing Notice for Certain Conservations Easements

Notice 2007-50 Qualified Conservation Contributions

Rev. Rul. 69-93 Nominal Payment on a Purchase Contract

Remainder Interests in Real Property


Rev. Rul. 78-303 Deductibility of a Donor's Remainder Interest in a Farm

Rev. Rul. 77-305 Deductibility of a Gift of a Remainder Interest in a Home

Stock/LLC/Partnership Gifts


Notice 2007-72 Gift/Repurchase of LLC

Rev. Rul. 67-178 The Amount of Cash Paid to an Organization to Reacquiring Stock, and not the Fair Market Value of the Stock When Transferred, is a Charitable Contribution

Stock Options


Rev. Rul. 2008-16 Substantiation for Combined Federal Campaign Gifts

Substantiation


Rev. Rul. 82-197 Deductibility of Stock Option Gifts

Tangible Personal Property


Rev. Rul. 80-233 Gifts of Bibles

Rev. Rul. 69-63 No Current Deduction for Gifts of Future Interests in Tangible Personal Property

Vehicles


Notice 2007-70 Vehicle Reporting Requirements

Rev. Rul. 2002-67 Gifts of Vehicles


POOLED INCOME FUNDS


Fund Creation


Rev. Rul. 85-57 Pooled Income Funds-Alternative Charitable Remaindermen

Rev. Rul. 82-38 Sample Provisions for a Pooled Income Fund

Rev. Rul. 72-196 Definition of a Pooled Income Fund

Fund Maintenance


Rev. Rul. 90-103 PIF Funded with Depletable or Depreciable Interests

Rev. Rul. 92-81 PIF Funded with Depletable or Depreciable Interests

Rev. Rul. 96-38 Pooled Income Fund Maintenance Requirements for a Community Trust

Rev. Rul. 92-108 Pooled Income Fund Maintenance Requirements for a Community Trust

Rev. Rul. 92-107 Pooled Income Fund Maintenance Requirements


PRIVATE FOUNDATIONS


Mergers, Reorganization and Termination


Rev. Rul. 2002-28 Filing Requirements for the Termination of a Private Foundation

Notice 2015-62 Investments Made for Charitable Purposes

T.D. 9740 Reliance Standards for Making Good Faith Determinations



SUPPORTING ORGANIZATIONS


Announcement 2010-19 Refund available for SO's Meeting Significant Voice Test

Announcement 2007-87 Payout Requirements

Notice 2007-21 DAFs and Supporting Organizations

Notice 2006-109 Treasury Guidance on SOs and DAFs

Rev. Rul. 76-208 Type III Supporting Organization (SO) Integral Support Level is 85% of Income


TAXATION


Rev. Rul 2021-2 Deductibility of certain expenses under the Paycheck Protection Program

Notice 2020-79 2021 Limitations Adjusted as Provided in Section 415(d)

Notice 2020-75 Forthcoming Regulations Regarding the Deductibility of Payments by Partnerships and S Corporations for Certain State and Local Income Taxes

Notice 2020-32 Guidance Regarding Deductibility of Certain Expenses Under the Paycheck Protection Program

Notice 2019-59 Limitations Adjusted As Provided in Section 4015(d)

Notice 2019-25 Expanded Penalty Relief for Taxpayers who Underwithheld

Notice 2019-11 Underpayment Penalty Relief

Notice 2019-9 Provided Interim Guidance on Sec. 4960 Excise Tax on Highly Compensated Nonprofit Employees

Notice 2019-7 Safe Harbor Test for Rental Real Estate

Notice 2017-64 2018 Limitations Adjusted as Provided in Section 415(d)

Notice 2015-57 Consistent Basis Reporting Between Estate and Person Acquiring Property from Decedent

T.D. 9725 Portability of a Deceased Spousal Unused Exclusion Amount

Notice 2014-79 Standard Mileage Rates

Announcement 2014-0007 Tax Treatment of Certain Alimony Paymentss

Notice 2014-70 2015 Limitations Adjusted as Provided in Section 415(d)

Notice 2014-21 How Existing Tax Principles Apply to Transactions Involving Virtual Currency

Notice 2013-80 2014 Standard Mileage Rates

Rev. Rul 2013-17 IRS Interprets Husband and Wife to Include Same-Sex Spouses

T.D. 9644 Guidance on the Computation of Net Investment Income and Net Investment Income Tax

T.D. 9629 Requirement of a Section 4959 Excise Tax Return and Time for Filing the Return

Notice 2012-52 Contributions to SMLLCs wholly owned by tax-exempt organizations are deductible

Notice 2012-40 The IRS issued Guidance on the Changes Required in 2013 for Sec. 125 Cafeteria Plans

Rev. Rul 2010-25 Homeowners May Deduct the Interest on Loans of $1.1 Million

T.D. 9514 Treasury Published Final Regulations on the Capital Gain Election by Composers of Musical Works.

Notice 2011-32 Earthquake and Tsunami Region of Japan are Qualified Disaster Areas.

Notice 2009-84 IRS Promises Limited Review of Protective Estate Claims

Notice 2009-82 IRS Notice on IRA Required Minimum Distribution (RMD) Holiday

Notice 2009-9 Guidance on 2009 IRA RMD Waiver

Notice 2007-45 Inspections of UBI Returns

Notice 2007-18 Tax Shelters Penalty Taxes

Rev. Rul. 2004-25 Federal Income Tax Rates

Rev. Rul. 81-7 Gift Tax and the Present Interest Test

Rev. Rul. 72-243 Sale of a Life Tenancy is the Sale of a Capital Asset

Rev. Rul. 69-545 A Nonresident Alien Individual is Entitled to only One Withholding Exemption

Rev. Rul. 66-106 Distributions from REIT are not UBTI


VALUATION


Estates and Gifts


T.D. 9797 Final Estate Basis Reporting Regulations

T.D. 9757 Estate Basis Reporting Proposed Regulations

Notice 2012-21 The IRS created a Special Category with a Six Month Additional Period to File IRS Form 706 and Elect Marital Portability

Rev. Rul. 2011-28 The IRS Determined that a Right of Asset Substitution is not an Incident of Ownership under Sec. 2042

Notice 2011-82 Must IRS Form 706 to Elect Marital Portability

Notice 2011-76 Six-month Extension for Filing Estate Tax Returns for 2010 Decedents

Notice 2011-66 Guidance for 2010 Estates

Notice 2008-32 Limitations Bundled Investment and Advisory Costs

Rev. Rul. 2008-22 Alternate Estate Valuation Date, Proposed Regs

Notice 2006-96 Alternate Estate Valuation Date, Proposed Regs

Life Insurance Policies


Rev. Rul. 2011-28 Substitution Not an Incident of Ownership

Rev. Rul. 2009-14 Tax Recognition of Insurance Death Benefits

Rev. Rul. 2009-13 income recognized upon the surrender or sale of the life insurance

Rev. Rul. 79-256 Reductions in Gift Values

Rev. Rul. 78-137 Valuing Insurance Policies

Planned Gifts


Notice 2009-18 Update for Actuarial Tables Under Section 7520

Remainder Interests


Rev. Rul. 76-473 Valuing the Remainder Interest in a Personal Residence

Stocks, Bonds and Other Business Units


Rev. Rul. 2008-35 No Restricted Management Account Discount

Rev. Rul. 93-12 Valuation of Stock for Intra-Family Transfers

Rev. Rul. 83-120 Valuing Stock in a Closely Held Business

Rev. Rul. 80-213 Valuing "Paired" Stock

Rev. Rul. 77-287 Valuing Stocks and Bonds

Rev. Rul. 55-278 Valuing U.S. Savings Bonds


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