IRS Priority Guidance Plan 2019-2020- Exempt Organizations

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On Oct. 8, 2019, the U.S. Treasury Department and the IRS released the 2019-2020 Priority Guidance Plan. The Priority Guidance Plan contains a list of guidance projects that Treasury and the IRS intend to focus on during the twelve-month period from July 1, 2019, through June 30, 2020. The 2019-2020 plan contains 203 guidance projects and prioritizes implementation of the 2017 Tax Cuts and Jobs Act (Pub. L. 115-97) and the 2019 Taxpayer first act (Pub. L. 116-25).

Projects listed on the 2019-2020 Priority Guidance Plan affecting tax-exempt organizations, tax-exempt bonds, and charitable giving are listed below.

Implementation of the Tax Cuts and Jobs Act

  • Regulations under section 274 concerning qualified transportation fringes, including the application of section 512(a)(7) (Notice 2018-99 published Dec. 10, 2018)
  • Regulations on computation of unrelated business taxable income for separate trades or businesses under section 512(a)(6) (Notice 2018-67 published Aug. 21, 2018)
  • Regulations on the increased contribution limit under section 529A, and final regulations under section 529A on qualified ABLE programs (proposed regulations published Oct. 9, 2019 and June 22, 2015, respectively)
  • Regulations under section 4960 regarding the excise tax on excess remuneration paid by “applicable tax-exempt organizations” (Notice 2019-09 published Dec. 31, 2018)
  • Final regulations on the excise tax on net investment income of certain private colleges and universities under section 4968 (proposed regulations published July 3, 2019)

Tax-Exempt Organizations

  • Guidance implementing section 3101 of the Taxpayer First Act on new electronic filing requirements for exempt organization returns
  • Guidance revising Rev. Proc. 80-27 regarding group exemption letters
  • Guidance on circumstances under which an LLC can qualify for recognition under section 501(c)(3)
  • Final regulations on section 506 regarding the notification requirement for organizations operating under section 501(c)(4) (final regulations published July 23, 2019)
  • Final regulations on section 509(a)(3) supporting organizations (proposed regulations published Feb.19, 2016)
  • Guidance under section 4941 regarding a private foundation’s investment in a partnership in which disqualified persons are also partners
  • Regulations regarding the excise taxes on donor-advised funds and fund management
  • Regulations and other guidance under section 6033 regarding exempt organization reporting and filing requirements (proposed regulations published Sept. 10, 2019)
  • Final regulations under section 6104(c) related to disclosure of certain information to state officials (proposed regulations published March 15, 2011)

Tax-Exempt Bonds

  • Guidance on private activity bonds under section 141
  • Guidance under sections 144(b) and 150 on qualified student loan bonds
  • Revenue procedure on the recovery of rebate under section 148
  • Guidance on direct payments for tax-advantaged bonds under section 6431
  • Guidance on tax-advantaged bond appeals procedures
  • Final regulations on bond reissuance under section 150 (proposed regulations published on Dec. 31, 2018)
  • Guidance on corrective actions for tax-advantaged bonds

Charitable Contributions

  • Guidance under section 170(e)(3) regarding charitable contributions of inventory

Other Items Affecting Tax-Exempt Organizations

  • Final regulations under section 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations (“VEBAs”) described in section 501(c)(9) (proposed regulations published Feb. 6, 2014)
  • Guidance under section 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government, and guidance on tribally chartered corporations
  • Final regulations on the fractions rule under section 514(c)(9)(E) (proposed regulations published Nov. 23, 2016)
  • Guidance regarding employee benefits plans of tax-exempt organizations and governmental entities, including VEBAs

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