The Service has ruled in technical advice that an organization is properly classified as a supporting organization under section 509(a)(3). At issue was whether the organization was controlled directly or indirectly by one or more disqualified persons. The Service determined it was not even though the foundation managers were disqualified persons with respect to a private foundation that was a substantial contributor to the supporting organization.  MORE »

The Service has ruled in technical advice that loans from a corporation that is a disqualified person with respect to a private foundation to another business entity, a portion of which is also owned by the private foundation, is not an indirect act of self-dealing under section 4941.  MORE »

In technical advice, the Service has ruled that an individual's bequest to a sister who belongs to a religious order and took a vow of poverty does not qualify for an estate tax charitable deduction.  MORE »

The IRS has ruled in technical advice that although an organization is no longer a church, it will retain its tax-exempt status and be subject it to intermediate sanctions for automatic excess benefit transactions and political intervention.  MORE »

The Service has ruled in technical advice that excise taxes under section 4958 should be imposed on the spouse of the founder of a charitable organization who used the foundation as a personal checking account for unrelated expenses. The Service recommended an initial 25 percent tax of the excess benefit and a 200 percent excise tax because the transactions were not corrected within the taxable period. In separate TAMs, the Service also recommended similar taxes be imposed on the founder, two sons, and son-in-law.  MORE »

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The Service has ruled in technical advice that no gift tax charitable deduction is allowed for transfers to a trust that is subject to four charities' withdrawal powers. Further ruled, each transfer is includable in the computation of adjusted taxable gifts to the trust's noncharitable beneficiaries.  MORE »

The Service has ruled in technical advice that an exempt organization's founder and former officer was a disqualified person under section 4958, that the officer received excess benefits, was subject to the organization manager tax, and was liable for penalties under sections 6684 and 6701.  MORE »

The Service has ruled in technical advice that a foreign national's estate was entitled to a charitable deduction for a charitable bequest made to a U.S. affiliate of a foreign charity.  MORE »

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