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Monday, June 6, 2016
Senate Finance Scrutiny of Private Museums Continues
According to this Chronicle of Philanthropy article (citing arts newsletter Hyperallergic), Senate Finance Committee Chair is continuing his scrutiny of private museums, now by requesting clarification from the IRS regarding its stance on private museums. You may recall that last fall, Senator Hatch sent a letter of inquiry to a number of private museums, requesting details regarding the museum's operation - fellow blogger Nickolas Mirkay detailed those letters here. Hyperallergic indicated that one of Hatch's primary concerns was the public availability of collections (including limited hours and advance reservations) and the continuing role of donor of the art collection in the management of the museums. Much of this scrutiny may stem from a series of New York Times articles regarding private museums, including here and here.
Inquiries of this type bother me somewhat. It seems to me that current law regarding private benefit is probably sufficient to handle many of the perceived abuses (maybe it's an enforcement issue - just throwin' it out there). The drumbeat of the articles and the Senate inquiry may lead to additional regulation - and I suspect they will use a mallet rather than a surgical instrument to deal with the issue, if history is any guide.
June 6, 2016 in Current Affairs, Federal – Executive, Federal – Legislative, In the News | Permalink | Comments (0)
Monday, May 2, 2016
Less Disclosure of Donors, More Disclosure of Applicants for Exemption?
In both Congress and the federal courts battles continue over disclosure of information relating to tax-exempt organizations. In California, a federal district judge ruled that California Attorney General Kamala Harris cannot force Koch brothers-related IRC section 501(c)(3) Americans for Prosperity Foundation (AFP) to provide a copy of the substantial donor list it files with the IRS (Schedule B to Form 990). While the decision was on an as-applied challenge and so only directly affects AFP, it was somewhat surprising given the earlier Ninth Circuit decision upholding the state disclosure requirement against a facial challenge. Whether the latest decision survives the almost certain appeal remains to be seen, however. Coverage: L.A. Times; Washington Post.
Not satisfied with the limited protected provided by this decision, Congress is now moving to eliminate the Schedule B entirely. H.R. 5053 cleared the House Ways and Means Committee late last week on a party-line vote, according to the Wall Street Journal (quoting LSU Professor Philip Hackney). The bill's fate is unclear, however, as it has already attracted public opposition from various outside groups, the N.Y. Times editorial board, and the Ranking (Democratic) Member of the Committee, according to the EO Tax Journal. It probably does not help its chances that the President for Government & Public Affairs at Koch Companies Public Sector, LLC publicly urged passage of the legislation.
UPDATE: Joint Committee on Taxation Description of H.R 5053; The Surly Subgroup Blog Post.
Finally, the Sixth Circuit recently moved the disclosure needle in the other direction with respect to applicants for recognition of exemption. In In re United States (United States v. NorCal Tea Party Patriots, et al.), the court resolved a discovery dispute by holding that the names, addresses, and taxpayer-identification numbers of applicants for tax-exempt status are not "return information" and so are not protected from discovery by IRC section 6103, even if their applications are pending, withdrawn, or denied. The only immediate effect of the decision is to allow the plaintiffs to identify possible class members in this class-action litigation arising out of the IRS Exempt Organizations Division selection of section 501(c)(4) applicants for additional scrutiny. But the larger ramification is that such information likely is now exposed to Freedom of Information Act requests that can be litigated in the Sixth Circuit, as section 6103 was the sole barrier to such requests. IRS Commissioner John Koskinen also suggested that some other types of IRS filings may also be exposed to public disclosure as a result of this decision. For those who may be interested in learning more about the ramifications of this case, I will be providing additional coverage in the "At Court" section of the ABA Tax Times' next issue. Additional coverage: Wall Street Journal.
Lloyd Mayer
May 2, 2016 in Federal – Executive, Federal – Legislative, In the News | Permalink | Comments (0)
Monday, April 11, 2016
Happy National Volunteer Week! Here's the grim legal side of altruistic labor
Happy National Volunteer Week! We know that volunteering can do lots of good, but what about when volunteering goes bad? Volunteer law is one of my primary scholarly interests, and in honor of the millions of Americans who volunteer each year, below are just a few of the ways that law deals with volunteering disasters. (But don't be deterred! Volunteers live longer, happier lives, and these problems probably won't happen to you or your organization.)
Volunteer Liability: Who gets sued when a volunteer commits a tort? The Federal Volunteer Protection Act provides a low level of immunity—with lots of exceptions and caveats—to volunteers for simple negligence. (Ask yourself whether regulation of unpaid labor fits within Congress's power under the commerce clause.) Some states also offer immunity of different flavors. Iowa immunizes volunteers for almost anything they do within the scope of their employment. Vermont immunizes volunteer librarians. (?!) Ohio just enacted a law immunizing volunteer architects. (Why architects? No idea. Underworked lobbyists, possibly.)
Fortunately, volunteers are rarely sued, and most suits involve intentional torts or accidents while driving (covered by insurance). (So, please don't sue me.)
Organizational liability: Organizations are liable for the acts of their agents under common law master-servant principles. This applies to employees and volunteers alike. But volunteers often interact with organizations in less formal ways than employees, and not always as simple to determine scope of "employment." Notably, immunity for the volunteer does NOT immunize the organization, making charities the prime defendant when suit is brought. Which, again, is fortunately pretty rare, especially for your small, community-based charity.
Volunteer Discrimination: Employers can't discriminate against employees on race, sex, religion, disability, and other protected characteristics. Sometimes, but not often, these laws also protect volunteers. (In fact, there is a circuit split about whether unpaid workers are covered under federal employee anti-discrimination laws.) Still, even if anti-discrimination isn't the law, be nice to your volunteers. It's the right thing to do.
Volunteers and Minimum Wage: One of the least settled areas of law involves application of minimum wage laws to volunteers. Cases are all over the place on this, and challenges involving unpaid interns and student-athletes add layers of confusion to the tests for charitable volunteers. Department of Labor has issued various informal "guidance" (read: no Chevron deference) on the topic of unpaid workers, but their positions are rejected by courts as often as they are upheld. Nevertheless, it would be pretty weird if your organization violated minimum wage laws by allowing someone to volunteer for your charity. (Not legal advice: just common sense.) One caveat is that a paid employee of your nonprofit can't "volunteer" for your organization performing the same type of services as would normally be paid to perform. (Note that the linked regulation only applies to government, but Department of Labor applies same rationale to nonprofits).
Much, much more could be said, which is why this is a fun area in which to write (not to mention volunteering as a rewarding personal pastime). Happy National Volunteer Week everyone!
April 11, 2016 in Current Affairs, Federal – Executive, Federal – Legislative | Permalink | Comments (0)
Friday, March 4, 2016
Tax Committee Chairmen Ask Questions About College and University Endowments
Last month the Boston Globe reported that the chairman of both the Senate Finance Committee and the House Ways and Means Committee sent joint letters to 56 colleges and universities with endowments of $1 billion or more. The letter asked 13 sets of questions covering topics ranging from categories of assets to management costs to spending policies. While it is now a common practice for the congressional tax writing committees to investigate various types of tax-exempt organizations - see the recent Senate Finance scrutiny of private museums opened by individual collectors and the 2008 Senate Finance letter to colleges and universities about their financial practices - it is interesting and perhaps significant that this latest inquiry is a joint one by committee chairmen in both chambers (including also the chairman of the House Ways and Means Subcommittee on Oversight). The current set of inquiries come in the wake of endowments (mostly) recovering from the Great Recession, a Congressional Research Service report focusing on college and university endowments, and prominent calls for wealthy educational institutions to provide more need-based financial aid (for example, see the recent NY Times Op-Ed by Victor Fleischer (San Diego)).
Additional coverage: BloombergBusiness; Inside Higher Ed.
Lloyd Mayer
March 4, 2016 in Federal – Legislative | Permalink | Comments (0)
Wednesday, March 2, 2016
House Oversight Subcommittee Hearing on "Protecting the Free Exchange of Ideas on College Campuses"
Georgetown University recently invoked Internal Revenue Code section 501(c)(3) as the basis for its policy prohibiting students from engaging in any political campaign activity on campus (see this The Hoya article for more details). Today the House Ways and Means Oversight Subcommittee held a hearing focusing on that policy and its alleged basis in the federal tax laws. Among others, Professor Frances Hill (University of Miami) provided testimony on the issue of whether such activities by students would be attributed to the University under section 501(c)(3) and so cause the University to violate that section's prohibition on political campaign intervention. As she details, the IRS has a long-standing, public position that generally the the political activity of students is not attributed to their schools, indicating that Georgetown University is incorrect in its assertion that federal tax law compels its current policy. That said, as a private institution the University is free to limit or even prohibit political activity on its property as long as it does so in a manner that does not favor a particular candidate or political party.
Hat tip: EO Tax Journal.
Lloyd Mayer
March 2, 2016 in Federal – Legislative | Permalink | Comments (0)
Wednesday, February 3, 2016
Archer: Combating Public Charity Fraud with Sarbanes Oxley
John George Archer (Law Student, Mississippi) has posted "This SOX: Combating Public Charity Fraud with Sarbanes-Oxley" to SSRN:
In the wake of the corporate scandals of the Enron era, Congress delivered the Sarbanes-Oxley Act (SOX) to bolster confidence in our nation's financial system. To save the system and protect the investing public from corporate abusers, Congress created a capable "toolkit" within SOX to fight fraud and enhance disclosure. Sarbanes-Oxley has been effective in stemming the tide of corporate malfeasance. Currently, only for-profit, publicly traded companies are subject to SOX. But corporate fraud does not stop at the door of the nonprofit world. Fraud within nonprofit corporations is a widespread problem, and nonprofits – particularly large public charities – share many similarities (the good and the bad) with their for-profit cousins. By drawing a parallel comparison between large public charities and publicly traded companies, this Article makes the case that the strong governance principles encapsulated by Sarbanes-Oxley should also be imposed on large public charities.
While others have either argued against applying SOX to nonprofits or have cautiously advocated this approach because of the diverse and varying missions of nonprofits, this article particularly singles out large public charities and demonstrates that SOX is an ideal regulator for this group. While state governments and the IRS both engage in nonprofit regulation, the current regime suffers from a lack of resources and enforcement measures to be truly effective. This is where SOX can help. So much of what Sarbanes-Oxley accomplishes is self-reporting and a governance structure that promotes independence and transparency. Because of this, Sarbanes-Oxley is considered best practices for large entities, and is voluntarily followed by many public charities.
Extending SOX would not be as large a leap as previously imagined. The parallel to large public charities is this: there is a disconnect between the stakeholders of a nonprofit and its directors and management. Within this gap lies the great potential for abuse and fraud. The economic impact of the nonprofit sector upon the American economy is no small thing, much less its social impact. To protect this vulnerable system and combat nonprofit abuse, this Article contends that Congress should take notice of the problem and address it using the same "toolkit" it already created when it addressed fraud among publicly traded companies.
Nicholas Mirkay
February 3, 2016 in Federal – Legislative, Publications – Articles | Permalink | Comments (0)
Wednesday, December 2, 2015
Senate Finance Committee Questions Public Benefit of Private Art Museums
As reported by The New York Times, the Senate Finance Committee sent letters to eleven private museums created and operated by opened by private collectors, focusing on whether sufficient public benefit is present to justify such museums' federal tax-exempt status. These letters were sent by chairman Senator Orrin Hatch (Utah) to galleries such as the Brant Foundation Art Study Center in Greenwich, Connecticut, Glenstone museum in Potomac, Maryland, the Rubell Family Collection in Miami, the Kreeger Museum in Washington, DC, and The Broad in Los Angeles, requesting additional information about visiting hours, donations, trustees, and valuations. Senator Hatch commented that: "Tax-exempt museums should focus on providing a public good and not the art of skirting around the tax code. While more information is needed to ensure compliance with the tax code, one thing is clear: Under the law, these organizations have a duty to promote the public interest, not those of well-off benefactors, plain and simple." The Senator's letter acknowledged the important role that charitable organizations play in our society, but questioned whether "some private foundations are operating museums that offer minimal benefit to the public while enabling donors to reap substantial tax advantages."
The New York Times article opined that the Hatch letters were sent after another of its articles published in January 2015 "examined the proliferation of tax-exempt private museums created by wealthy art collectors, sometimes in their own backyards. Some of the galleries severely limit public access, closing their doors to outsiders for several months at a time, shunning signs and advertisements, and requiring visitors to make advance reservations." According to the article, this inquiry was part of a broader effort to re-examine institutions, including private museums and universities, which have enjoyed tax-exempt status for many decades.
Nicholas Mirkay
December 2, 2015 in Federal – Legislative, In the News | Permalink | Comments (0)
Friday, September 18, 2015
8th Circuit Rules ACA Opt-Out Provision May Violate RFRA
As reported (slightly imprecisely from my legal perspective) in Reuters, the United States Court of Appeals for the 8th Circuit, parting ways with other appellate courts deciding the issue, has issued two rulings lending support to the position that the Affordable Care Act ("ACA") violates the rights of religiously affiliated employers by forcing them to take action that they sincerely believe would constitute complicity in the provision of contraceptive coverage, including abortifacients. The cases are Dordt College v. Burwell and Sharpe Holdings, Inc. v. United States Department of Health and Human Services. This post will highlight language from Sharpe Holdings.
As many readers are aware, regulations under the ACA require nonexempt employers to provide their employees with insurance coverage for FDA-approved contraception, which, as the United States Supreme Court has recognized, includes drugs that may prevent a fertilized egg from attaching to the uterus. The same regulations permit certain religious organizations that object to providing such coverage to opt out of the coverage by filing a form with their third party administrators or by notifying the Department of Health and Human Services of their objection. In Sharpe Holdings, the plaintiffs argued that "both the contraceptive mandate and the accommodation process impose a substantial burden on their exercise of religion in violation of the Religious Freedom Restoration Act of 1993 (RFRA)." More precisely, the plaintiffs "contend that the government is coercing them to violate their religious beliefs by threatening to impose severe monetary penalties unless they either directly provide coverage for objectionable contraceptives through their group health plans or indirectly provide, trigger, and facilitate that objectionable coverage through the Form 700/HHS Notice accommodation process." Accordingly, they petitioned the district court to "enjoin enforcement of the contraceptive mandate and the accommodation regulations against them." The district court granted the requested injunctive relief.
The United States Court of Appeals for the 8th Circuit in Sharpe Holdings affirmed the district court's order granting injunctive relief. The appellate court concluded that the district court "did not abuse its discretion in finding that [two nonprofits] were substantially likely to succeed on the merits of their claim that the contraceptive mandate and the accommodation process substantially burden their exercise of religion in violation of RFRA and that the current accommodation process is not the least restrictive means of furthering the government's interests."
In accepting the plaintiffs' argument that the ACA regulations substantially burdened their exercise of religion, the court relied heavily on the Supreme Court's Hobby Lobby decision:
As Hobby Lobby instructs, however, we must accept CNS and HCC's assertion that self-certification under the accommodation process—using either Form 700 or HHS Notice—would violate their sincerely held religious beliefs. See Hobby Lobby, 134 S. Ct. at 2778; see also Hernandez v. Comm'r, 490 U.S. 680, 699 (1989) ("It is not within the judicial ken to question the centrality of particular beliefs or practices to a faith, or the validity of particular litigants' interpretations of those creeds."). It is not our role to second-guess CNS and HCC's honest assessment of a "difficult and important question of religion and moral philosophy, namely, the circumstances under which it is wrong for a person to perform an act that is innocent in itself but that has the effect of enabling or facilitating the commission of an immoral act by another." Hobby Lobby, 134 S. Ct. at 2778. As discussed above, Form 700 or HHS Notice will inform CNS and HCC's TPA of its obligations to facilitate contraceptive coverage for CNS and HCC's employees and plan beneficiaries and thus will play a part in providing the objectionable contraceptives. As in Hobby Lobby, CNS and HCC sincerely believe that the actions "demanded by the . . . regulations [are] connected to" illicit conduct "in a way that is sufficient to make it immoral for them to" take those actions. Id. CNS and HCC have drawn a line between actions they find "to be consistent with [their] religious beliefs" and actions they consider "morally objectionable." Id. (citing Thomas, 450 U.S. at 715). And it is not for us "'to say that the line [they] drew was an unreasonable one.'" Id. (quoting Thomas, 450 U.S. at 715); see also Priests for Life, slip op. at 12 (Kavanaugh, J., dissenting from denial of rehearing en banc) ("Judicially second-guessing the correctness or reasonableness (as opposed to the sincerity) of plaintiffs' religious beliefs is exactly what the Supreme Court in Hobby Lobby told us not to do.").
In holding against the government on whether the ACA regulations are the least restrictive means for furthering a compelling government interest, the 8th Circuit emphasized the government's burden of proof on the issue, and found that it "has not shown that these [several possible] alternatives [discussed in the opinion] are infeasible."
September 18, 2015 in Church and State, Federal – Legislative | Permalink | Comments (0)
Thursday, September 17, 2015
GAO Report on American Red Cross Released; Federal Legislation Proposed
NPR reports that the "American Red Cross is facing new criticism today as government investigators and a congressman call for independent oversight over the long-venerated charity." NPR explains that Representative Bennie Thompson has introduced a bill called the American Red Cross Sunshine Act on the heels of the release of a report by the United States Government Accountability Office ("GAO") that examined the charity's operations. The GAO report, says NPR, "finds oversight of the charity lacking and recommends that Congress find a way to fill the gap."
The "Conclusions" section of the GAO report states as follows:
The nation's disaster response system relies to a significant extent on the nonprofit sector, which harnesses the public's generosity to provide funding for disaster response and recovery efforts. This approach can support the nation's efforts to assist disaster victims, but it also has limited accountability for disaster assistance. The Red Cross, the organization most responsible for providing shelter and other mass care services to disaster victims, exemplifies this tension. It has been designated by law as an instrumentality of the United States and has a critical, formalized role in coordinating and providing disaster response services across the nation. At the same time it remains a nonprofit organization that generally makes its own decisions about what services to provide. This reliance on an independent organization can be effective if government and the donating public have confidence that [the] Red Cross is providing the services that are most needed in an effective and efficient manner. Further, in disasters in which the federal government is involved, the extent and effectiveness of the Red Cross's activities could have a direct impact on the nature and scope of the federal government's activities.
With regard to oversight, while the Red Cross has some internal evaluation processes in place, such as after action reviews and surveys of state emergency managers and other stakeholders, Red Cross officials told us that the results of their internal evaluations are typically not made available to the general public. The absence of regular, external evaluations of its disaster services that are publicly disseminated could affect the confidence of both the donating public and the federal agencies that rely on the Red Cross. This is especially true in light of questions raised by the federal government and others in recent years about the organization's performance in disasters. Given the Red Cross's status as an instrumentality of the United States and the critical responsibilities assigned to it by its federal charter and by federal policies, the federal government has a clear stake and role in ensuring that proper oversight takes place.
In a section entitled "Matters for Congressional Consideration," the GAO report further recommends legislative action:
To maintain governmental and public confidence in the Red Cross, Congress should consider establishing a federal mechanism for conducting regular, external, independent, and publicly disseminated evaluations of the Red Cross's disaster assistance services in domestic disasters in which the federal government provides leadership or support. This mechanism might involve annual evaluations of whether the services achieved their objectives or of their impact on disaster victims. This evaluation could be performed, for example, by a federal agency such as DHS, by an IG office such as the DHS IG, or by a private research firm under contract to a federal agency.
The American Red Cross Sunshine Act, according to its preface, would "enhance oversight of the American National Red Cross by the Government Accountability Office and Inspectors General at the Departments of Homeland Security, Treasury, and State," and would require the Department of Homeland Security to conduct a pilot program with the charity to research and develop mechanisms to improve the charity's preparedness and response capabilities through social media.
Additional Coverage: The Chronicle of Philanthropy
September 17, 2015 in Current Affairs, Federal – Executive, Federal – Legislative | Permalink | Comments (0)
Thursday, August 13, 2015
Tax-Exempt Status of Religious Universities & Institutions after Same-Sex Marriage Ruling
The Supreme Court ruling on same-sex marriage has yielded a lot of commentary regarding its potential effect on tax-exempt, religious organizations, including religiously-affiliated educational organizations. The Washington Post article referenced below sets forth the IRS Commissioner's commitment to not change its stance and begin revoking the exemption of religiously-affiliated educational institutions that oppose the ruling. The second set of blog posts looks at the issue more broadly, generally making the argument that opposition from such educational and other religious institutions results in "vibrant" and essential pluralism.
Washington Post, "IRS Commissioner Promises to Not to Revoke Tax-Exempt Status of Colleges that Oppose Gay Marriage":
After the Supreme Court's decision on gay marriage, religious leaders feared that religious universities, nonprofits and other institutions could lose their tax-exempt status. IRS Commissioner John Koskinen has promised the Senate Judiciary Oversight Subcommittee that his agency would not go after the tax-exempt status of religious colleges and universities that oppose gay marriage.
During a hearing Wednesday conducted by the Senate Subcommittee on Oversight, Agency Action, Federal Rights and Federal Courts, Sen. Mike Lee (R-Utah) asked Koskinen whether the IRS would "not, in the absence of a directive by Congress or by the courts," take action to remove religious schools' tax exemption.
"I can make that commitment," Koskinen said, explaining that "we see no basis for changing our examination criteria as a result of this Supreme Court case."
Koskinen discussed the potential for such schools' tax exemption to go under scrutiny down the road. "If we ever did that, we would issue it for public comment. There would be no surprises," Koskinen said. "The public would have plenty of notice and plenty of opportunity to comment, and that's not going to happen in the next two and a half years." [emphasis added]
[Hat tip: TaxProfBlog] [see also Philanthropy News Digest; The Hill]
PrawfsBlog, "Garnett et al. on Tax-Exempt Status and Religious (and Other) Organizations" by Paul Horwitz (Alabama)::
Should government insist that all private organizations comply with its own sense of the good? Most people, I think, still agree that the answer to this question is no. However strongly they feel that those public values are the right values, and however devoutly they may hope that all people and all groups come to share them and to act accordingly, they still believe for various reasons--not least a sense that the public-private distinction, however imperfect and vulnerable to critique, represents an important value of its own--that government should not and perhaps cannot rigorously or ruthlessly enforce what Nancy Rosenblum has called a "logic of congruence" between public and private organizations. ...
Our friend and fellow Prawfs writer Rick Garnett discusses that question in a new editorial co-written with John Inazu and Michael McConnell [see below]. The title, which I gather its writers did not choose and might not be completely comfortable with, is "How to Protect Endangered Religious Groups You Admire." They argue, in brief, that we should, at a minimum, be willing to protect religious non-profits that provide significant contributions to the public good despite their now heterodox views.
Read the whole thing. Feel free to disagree. I will add two points. I agree, in sensibility at least, with a point made by Marc DeGirolami in a recent post about the editorial: "We use the language of 'exemption' when we speak of the taxable status of nonprofits, but it would be better instead to think of their nontaxable status as marking a boundary of the government's power to tax." Reasonable disagreement is available about whether "power" is an apt word here, but for those who believe that whatever the extent of state power, it ought not lightly be exercised in a way that circumscribes civil society and a vibrant pluralism, the sensibility is right. Second, it ought not be only pluralists, and certainly not only social conservatives, who support these arguments. This is an argument that liberals ought to be taking seriously now, especially as progressive thought continues to drift in a more illiberal direction.
Christianity Today op-ed: How to Protect Endangered Religious Groups You Admire, by Richard W. Garnett (Notre Dame), John D. Inazu (Washington University) & Michael W. McConnell (Stanford):
Today, tens of thousands of religious organizations, and tens of millions of Americans, continue to believe and teach that the proper understanding of marriage is a union of one man and one woman. But they do far more than believe and teach this and other views.
They also give food, clothing, shelter, counsel, and comfort to millions of Americans in need. They offer some of the most important and desperately needed health, educational, and social services in the country. And they provide billions of dollars and thousands of full-time workers for international relief aid that serves vulnerable migrants, refugees, and persecuted minorities. The work of religious organizations has long been and continues to be central both to religious believers' lives and to the welfare of others. Our communities—and, indeed, communities around the globe—would be much worse off without these organizations and their faith-informed good works.
Despite the crucial role that religious organizations and individuals have long played in our country, some voices now suggest that they and their work are somehow tainted because of their beliefs about marriage and sexuality. Some argue that the time has come to push religious believers out of the public square and confine them to the quiet, private realm of personal prayer and worship. This despite the Supreme Court's recent decision in Obergefell v. Hodges, which not only required states to legally recognize same-sex marriages but also said, "the First Amendment ensures that religious organizations and persons are given proper protection as they seek to teach the principles that are so fulfilling and so central to their lives and faiths."
Nonetheless, because of their traditional views on human sexuality, religious organizations have already been threatened with heavy-handed government action. ...
[W]ithin days of the Court's decision in Obergefell, New York Times columnist Mark Oppenheimer wrote that the government should eliminate tax-exempt status from "organizations that dissent from settled public policy on matters of race or sexuality."
Mr. Oppenheimer failed to acknowledge that in a pluralistic and democratic society, government routinely recognizes the tax-exempt status of organizations that differ from "settled public policy." For example, not that long ago, the Human Rights Campaign was tax-exempt when it differed from settled policy on matters of sexuality; the same is true of organizations, like the Sierra Club, who push for changes in environmental regulation, or anti-war groups, who oppose US military policy. One of the principal purposes of civil society organizations is to challenge "settled public policy."
Moreover, the majority opinion in the 5-4 decision in Obergefell earlier this summer made clear that "Many who deem same-sex marriage to be wrong reach that conclusion based on decent and honorable religious or philosophical premises, and neither they nor their beliefs are disparaged here." ...
Some members of Congress have now introduced the First Amendment Defense Act (FADA) in an effort to ensure that overheated rhetoric and political opportunism do not endanger the important work of faith-based organizations. The core of FADA would require the federal government to honor its longstanding commitments to treat all such organizations with an even hand. It would prevent federal officials from attempting to strip tax-exempt status, from denying equal access to federal facilities and entitlements, or from taking adverse actions related to licensing or accreditation. ... We think the best approach is to tailor FADA to the core area of concern: religious nonprofits. That focus would serve the cause of religious freedom by making it more likely that this important legislation can move forward.
[Hat tip: TaxProfBlog]
Nicholas Mirkay
August 13, 2015 in Federal – Executive, Federal – Legislative, In the News | Permalink | Comments (0)
Friday, July 24, 2015
More on Political Activity Referrals and Political Activity Regulations
As previously blogged, the GAO Report to Congress (the full report is here) on the IRS processes for political activity referrals found significant deficiencies with respect to the initial allegations that triggered an audit. In some cases, no case files were found by the GAO. These deficiencies "increase the risk that EO could select exempt organizations for examination in an unfair manner - for example, based on an organization's religious, educational, political or other views." According to Bloomberg BNA, in the hearing before the Ways and Means Oversight Committee in which the GAO report was released, it was determined that for the past six years, "one person working alone at the IRS has been deciding which complaints about the political activities of exempt organizations should be followed up."
Following the above-referenced hearing, IRS Commissioner John Koskinen reported to Bloomberg BNA that final regulations on political campaign activities by exempt organizations will not be in place prior to the 2016 presidential election (see proposed regulations here). The regulations will likely not be effective until January 2017. See prior blog posts on the proposed regulations and political activity regulations generally (April 16, 2014; July 16, 2015).
Nicholas Mirkay
July 24, 2015 in Federal – Executive, Federal – Legislative, In the News | Permalink | Comments (0)
Monday, July 20, 2015
First Amendment Defense Act Would Protect Tax-Exempt Organizations
As reported by The New York Times, Representative Raúl R. Labrador, Republican of Idaho, and Senator Mike Lee, Republican of Utah, along with 130 sponsors, have proposed legislation, the First Amendment Defense Act, that would confer protections for tax-exempt organizations and individuals that object to the Supreme Court's recent gay-marriage ruling on religious or moral grounds. The Act specifically provides that the Federal government cannot take any "discriminatory action" against a person, "wholly or partially on the basis that such person believes in accordance with a religious belief or moral conviction that marriage is or should be recognized as the union of one man and one woman, or that sexual relations are properly reserved to such a marriage." The Act defines a "discriminatory action" to include (i) an action by the Federal government to "alter in any way the Federal tax treatment of, or cause any tax, penalty or payment to be assessed against, or deny, delay, or revoke an exemption from taxation under Section 501(a) of the Internal Revenue Code of 1986 of, any person" referred to above, or (ii) "disallow a deduction for Federal tax purposes of any charitable contribution to or by such person." The Act states that it should be broadly interpreted in favor of a 'broad protection of free exercise of religious beliefs and moral convictions, to the maximum extent permitted" by the Act and the U.S. Constitution.
The Times reports that a bill proposed by "moderates" would attached two pro-gay rights provisions: (i) the Employment Non-Discrimination Act, making illegal workplace discrimination based on sexual orientation, and (ii) an amendment to the Fair Housing Act to include protections on the basis of sexual orientation and gender identity.
The Act, if passed in its present form, would ostensibly address the concerns of churches and other religiously-affiliated organizations that their tax-exempt status could be revoked for discrimination in membership or employment or otherwise on the basis of sexual orientation, even if such organizations' actions are based on their core religious tenets. (See prior blog post here discussing these concerns).
Nicholas Mirkay
July 20, 2015 in Current Affairs, Federal – Legislative | Permalink | Comments (0)
Tuesday, June 9, 2015
Nothing But Sheet Metal to See Here... For Now.
You may have been following the FOIA lawsuit by Public.Resource.org, (a Section 501(c)(3) organization headed by Carl Malamud that is dedicated to open government) against the IRS. Public.Resource.org filed a FOIA request for information on the Sheet Metal and Air Conditional National Association (SMACNA) and its affiliated entities (the original complaint is here), but demanded that the IRS turn over the information in electronic format (not paper copy). The IRS resisted, arguing that it was administratively burdensome and that the paper copies were sufficient. In January of this year, however, the District Court ordered the IRS to turn over the electronic files of the requested Forms 990 within sixty days.
Sixty days came and went. Appeals happened. According to The Chronicle of Philanthropy, however, it looks like the IRS apparently finally released the SMACNA documents this week (the documents are here). Of greater interest (not that sheet metal isn't interesting, … I guess… ) is the article's report that the IRS is dropping its appeal. Given that Malamud wants the IRS to create a fully searchable database of all electronically filed Forms 990, I wonder what comes next? Will the IRS voluntarily comply with electronic file FOIA requests? In the process of responding to this law suit, did the IRS set up a procedure that could be replicated easily? Are they going the full database route – according to the article, it appears that discussions are underway. In the grand scheme of things, such a database would be very useful, but so would a great number of things administratively at the IRS. After all, the IRS has so many spare folks sitting around with nothing to do…
As an aside, I wondered why the sheet metal folks drew the ire of Public.Resource.org – the backstory appears to be that Public.Resource.org investigated and sued the SMACNA with regard to the association's efforts to have its standards incorporated into state and local safety codes.
June 9, 2015 in Federal – Judicial, Federal – Legislative, In the News | Permalink | Comments (0)
Thursday, May 14, 2015
501(c)(4) Update: TIGTA Final Report, FOIA Requests, More Emails, Pending Legislation
The Treasury Inspector General for Tax Administration issued a new "Final Report" on the IRS handling of exemption applications involving political campaign intervention. Here are excerpts from the conclusions:
The IRS has taken significant actions to eliminate the selection of potential political cases based on names and policy positions, expedite processing of Internal Revenue Code (I.R.C.) Section (§) 501(c)(4) social welfare organization applications, and eliminate unnecessary information requests.
First, the IRS eliminated the use of Be On the organizations, if it becomes a permanent Look Out (BOLO) listings, . . . .
Second, the Exempt Organizations function completed processing for 149 of the 160 applications for tax-exempt status that, as of December 2012, had been open for lengthy periods. . . . .
The report further provides that in the absence of BOLO listings the IRS has created an "Emerging Issues Committee" to screen, review, and monitor emerging issues based on actual or planned activities of applicants, as opposed to names or policy positions. The report also provides of 149 closed applications, the IRS approved 107 (72%) and disapproved 7 (5%), while applicants either withdrew (8 or 5%) or failed to respond to requests for information (27 or 18%) the remaining applications. Of the 11 applications still open, six are in litigation and five have either proposed adverse determinations or are in Appeals. Reading between the lines, a Bloomberg article notes that these figures suggest that the IRS has sent Crossroads GPS a denial letter, since the Crossroads application is still outstanding and is not in litigation. As the Center for Responsive Politics notes, however, the statute of limitations might now bar collection of any taxes from Crossroads even if its application is ultimately denied. Additional Coverage: Forbes (Peter Reilly).
Relatedly, the NorCal Tea Party Patriots have convinced the federal judge overseeing their lawsuit against the IRS to require the IRS to identify the 298 groups that had submitted applications identified as potential political cases as of May 31, 2012 (mentioned on page 4 of the TIGTA Final Report) in order to facilitate class certification in that litigation. The Judge's order explains why she concluded Internal Revenue Code section 6103 does not prevent this limited discovery. Additional coverage: Forbes (Peter Reilly).
In other news, TIGTA managed to recover 6,400 emails to or from Lois Lerner from between 2004 and 2013, although it is unclear how many might be duplicates of the tens of thousands of emails previously recovered by the IRS and turned over to Congress. No final word from the congressional committees reviewing the emails regarding whether they add anything to the ongoing investigations, although initial indications are that there is little new in them. Coverage: CNN; Forbes (Kelly Phillips Erb); The Hill.
Finally, the House has passed a package of bills relating to the 501(c)(4) application mess, although their fate in the Senate (and on the President's desk) is uncertain. The most prominent is H.R. 1104, which would extend a gift tax exemption to 501(c)(4) social welfare organizations, 501(c)(5) labor, agricultural, and horticultural organizations, and 501(c)(6) trade associations and chambers of commerce. Currently donors to 501(c)(3) charities generally enjoy such a deduction (under Internal Revenue Code section 2522), and transfers to 527 political organizations are exempt from the gift tax (under section 2501(a)(4)). The other bills are H.R. 709 (termination for political targetting), H.R. 1026 (taxpayer privacy), H.R. 1058 (Taxpayer Bill of Rights), H.R. 1152 (use of personal email accounts prohibition), H.R. 1295 (self declaration process and declaratory judgment actions for 501(c)(4)s), and H.R. 1314 (right to appeal). Coverage: Forbes (Robert W. Wood); Politico.
Lloyd Mayer
May 14, 2015 in Federal – Executive, Federal – Legislative, In the News | Permalink | Comments (0) | TrackBack (0)
Thursday, April 30, 2015
College Fraternities and Sororities Lobby for Indirect Tax Benefit
The Washington Post reports that the Fraternal Government Relations Coalition, which represents 100 fraternities and sororities collectively owning $3.2 billion in real estate, "is lobbying Congress this week to urge legislators to pass a bill that would allow charitable donations to fund up to $1 billion in housing construction for Greek-letter houses across the country." The story reports that lobbyists justify the tax expenditure on grounds of safety, lowering costs of student housing, spurring small business jobs, and granting "tax parity between the colleges and the Greek houses that serve the same students."
I did a little digging, and I am finding some curiosities with the Post's legal analysis. The Post reports that the lobbyist group is urging adoption of the Collegiate Housing and Infrastructure Act, and that the "current bill, H.R. 1718, is sponsored by Rep. Pete Sessions (R-Tex.) and has 14 bipartisan sponsors." The story further states that the bill would amend the Internal Revenue Code "to allow donations to Greek groups for student housing to be fully tax deductible." But according to the text of H.R. 1718, the general rule of the proposed legislation simply states as follows:
For purposes of subsection (c)(3) and sections 170(c)(2)(B), 2055(a)(2), and 2522(a)(2), an organization shall not fail to be treated as organized and operated exclusively for charitable or educational purposes solely because such organization makes collegiate housing and infrastructure grants to an organization described in subsection (c)(7) which applies the grant to its collegiate housing property.
Thus, the bill in question would only indirectly do what the story says, insofar as a section 501(c)(3) entity receiving tax-deductible contributions could use donated funds to finance the construction or refurbishing of fraternity and sorority houses owned by those section 501(c)(7) entities.
The story also mysteriously states as follows:
Under current tax rules, just 30 percent of a single donation to a Greek organization for housing is considered tax deductible. The bill would permit as much as 100 percent of the donation to be deductible, which already is allowed for donors who give directly to universities and colleges.
I have no idea why the Post reports that "30 percent of a single donation to a Greek organization for housing is considered tax deductible" under current law. Fraternities and sororities are tax-exempt as section 501(c)(7) entities, not section 501(c)(3) entities qualifying for tax-deductible donations under Code section 170(c)(2).
But my main concern is not with the misleading technical analysis of the Post. I am quite skeptical that this proposed tax expenditure is justified. The IRS long ago issued a revenue ruling that supports the deductibility of charitable contributions to universities that use the donations to build housing owned by the universities and leased to fraternities and sororities. See Rev. Rul. 60-367, 1960-2 C.B. 73. Here are the key excerpts from the ruling:
A college might properly adopt as incident to its educational activities a program to assist in the housing of all its students by providing dormitories, by providing an information or rental office to obtain accommodations for its students in private homes, by exercising control over housing for its students, by purchasing or constructing, owning and operating houses for fraternity students, or by a combination of such activities. The furnishing of housing for fraternity members would not cease to be a college activity because the college participated in or undertook plans to have the whole or a part of the cost of a fraternity house defrayed by gifts from alumni of a particular fraternity. In order, however, for the gift to be deductible as a gift to the college, it must in reality be a gift to the college and must not be a gift to the fraternity by using the college as a conduit.
The effect of designation by a donor as to the fraternity house for which his gift is to be used must not be such that his gift is for the benefit of the fraternity rather than for the benefit of the college. Therefore, the college must, as the result of the gift, have the attributes of ownership in respect of the donated property, and its rights as an owner must not, as a condition of the gift, be limited by conditions or restrictions which in effect make a private group the beneficiary of the donated property. The making and acceptance of a gift on conditions which confer substantial rights on a private group are inconsistent with a gift wholly to the college. The college should, as an owner, be free to use the property acquired with the gift as its future policy suggests or requires.
I do not believe that the proposed bill is necessary to achieve the benefits claimed by the lobbyists. Construction and renovation of university-owned housing generates just as much economic boom as that associated with privately owned housing, and it is easier for a university to ensure that frat housing is safe and affordable if the university is in charge of it than if a frat is. Further, in light of recent nationally publicized events associated with Greek life, I would modestly suggest that policies promoting greater university control of fraternity and sorority housing are not necessarily a bad idea.
So here's an alternative idea. Keep current law in place. Universities can welcome donations of existing Greek houses to the universities, which would then lease the houses back to the section 501(c)(7) entities on terms that ensure fair student housing prices and safe conditions. And if the fraternities violate anti-hazing or anti-discrimination policies of the universities, they have breached their leases and must find new safe, affordable housing.
April 30, 2015 in Federal – Legislative | Permalink | Comments (0) | TrackBack (0)
Friday, January 30, 2015
Senator Grassley Targets a Missouri Nonprofit Hospital for its Billing and Collection Practices
As reported in the Daily Tax Report and as released in a statement from his office, Senator Grassley is requesting that a Missouri non-profit hospital, Mosaic Life in Care in St. Joseph, Missouri, explain its large number of lawsuits against low-income patients over treatment bills rather than providing such patients reasonable payment plans for their medical care. In a letter to the hospital, the Senator affirmed Mosaic's requirement to confer community as a condition to its tax-exempt status as well as meet other requirements under the law, including a financial assistance policy and constraints on billing and collection practices. In his statement, the Senator explained:
Non-profit hospitals are obligated under law to have a financial assistance policy and alert those who can't afford care of any assistance they qualify to receive. Occasionally, a hospital seems to go out of its way to avoid helping the poorest patients. When these cases come up, the hospitals should explain their practices and how they comply with the spirit and the letter of the law. It's a matter of accountability for the tax breaks they receive.
Nicholas Mirkay
January 30, 2015 in Federal – Legislative, In the News | Permalink | Comments (0) | TrackBack (0)
Saturday, November 29, 2014
Update on Nonprofits & Politics: Aprill and Colinvaux Articles, AALS Program, IRS Controversy Developments & More
While perhaps the congressional attention to the now 18 months old and counting IRS controversy will decline as the focus shifts to governing (we hope) and 2016 (unavoidably), the bubbling pot that is now nonprofits and politics continues to boil. Here are some of the latest developments:
Ellen Aprill (Loyola-L.A.) has posted The Latest Installment of the Section 501(c)(4) Saga: The Section 527 Obstacle to Effective Section 501(c)(4) Regulations, and Roger Colinvaux (Catholic) has posted Political Activity Limits and Tax Exemption: A Gordian's Knot, Virginia Tax Review (forthcoming). (And, as noted by Paul Caron when I presented at Loyola-L.A., I am working on a draft article currently titled Taxing Politics, which I should hopefully be able to post early in the new year.)
At the 2015 AALS Annual Meeting, the Section on Nonprofit and Philanthropy Law and the Section on Taxation are co-sponsoring IRS Oversight of Charitable and Other Exempt Organizations – Broken? Fixable? on Saturday, January 3rd, from 10:30 a.m. to 12:15 p.m. The topic grew out of the IRS controversy, although the panel's scope will be much broader. Marcus Owens (Caplin & Drysdale) will be moderating, and panelists include Ellen Aprill (Loyola-LA), Phil Hackney (LSU), Jim Fishman (Pace), Terri Helge (Texas A&M), Dan Tokaji (Ohio State), and Donald Tobin (Maryland).
In news relating directly to the IRS controversy, the staffs of the Senate Permanent Subcommittee on Investigations issued dueling reports, neither of which said much more than we have already heard (repeatedly) from both sides of the aisle. At the IRS, new TE/GE Commissioner Sunita Lough issued her annual Program Letter, emphasizing accountability and transparency as she continues to try to move the division beyond the controversy (referenced obliquely as "the challenges over the last year for the IRS and TE/GE specifically"). And to the annoyance of her critics, Lois Lerner gave an extensive interview to Politico.
And there is more:
- Pulpit Freedom Sunday 2014 launched on October 5th, to very limited media coverage, although there were a few stories right around election day about the over 1600 participating pastors and churches. See the stories in Politico, a Washington Post blog, and the Washington Times.
- On the election law/FEC side of things, there are lawsuits still pending that asset Crossroads GPS (Public Citzen v. FEC) and American Action Network and Americans for Job Security (CREW v. FEC) should have registered and reported as political commitees. (Hat tip: Paul Barton's article this past week in the BNA Daily Tax Report)
Lloyd Mayer
November 29, 2014 in Church and State, Federal – Executive, Federal – Judicial, Federal – Legislative, In the News, Publications – Articles | Permalink | Comments (0) | TrackBack (0)
Saturday, July 19, 2014
Assessment of the "America Gives More Act"
Unsurprisingly, the U.S. House passed charitable giving legislation, the "America Gives More Act," on July 17 by a vote of 277-130. (For a summary of the bill's contents, see prior blog post.) Broadly, the bill would encourage food donations, transfers from IRAs, conservation easement donations, extend the time to claim charitable deductions to April 15, and reduce the tax on private foundation investment income. According to the Joint Committee on Taxation, the legislation would cost taxpayers $16.2 billion over ten years.
Supporters of the bill (mostly Republicans) emphasized familiar themes. Charitable giving legislation is good because giving helps those in need (see, e.g., Chairman Camp's floor statement, Majority Whip McCarthy's statement) and because giving itself should be encouraged. The bill was also praised as a simplification (Statement of Representative Griffin) (though only one of the five provisions simplifies the Code).
Opponents of the bill (all Democrats, but one), though praiseworthy of charitable giving in general, cited in particular the failure to pay for the tax benefits and the resulting increase in the deficit. (Floor statement of Representative Levin, the White House.) The White House also objected that the giving incentives would benefit high-income taxpayers. One Democrat, Representative Lloyd Doggett, objected on substantive grounds, saying that the incentives for donations of food inventory encouraged donations of items with "no nutritional value, like Twinkies, candy, stale potato chips, and expired foods." "We do not need a permanent tax break for Twinkies" he said. (Video of Mr. Doggett's commentary on the food proposal here.)
How to assess the legislation? Helping "the needy" certainly is a familiar rationale cited in support of charitable giving legislation. But it bears repeating that "the needy" is but one segment of the 501(c)(3) sector. (Additional commentary on who benefits from the charitable deduction here). Broad-based charitable giving incentives such as extending the filing deadline and encouraging more IRA transfers are not directed toward helping the needy. Thus, if this really is a goal of lawmakers, much more targeted legislation to benefit social safety net organizations would be more appropriate.
Further, it is hard to ignore the absence of offsets. When tax benefits like these are not paid for, the question should be whether the America Gives More Act is the best use of $16.2 billion dollars. It is ironic that about 64 percent of the Act's cost comes from extending two provisions (the special rule for food donations and the exclusion for IRA distributions) that were allowed to expire in the Tax Reform Act, which undermines the argument that this legislation is an optimal use of tax dollars.
Other provisions have some merit, depending on the goal. Extending the time to claim donations to April 15 may be a cost effective way to get more dollars to 501(c)(3) organizations, assuming the IRS can administer the provision to protect against double deductions.
Streamlining the excise tax on private foundations will likely result in diverting dollars from the U.S. Treasury to foundation grantees – sort of an inter-501(c)(3) sector transfer. This may be desirable, depending on one's judgment about whether foundations or the government spends money more in the public interest. But the provision does not result in new charitable dollars and so is not a giving incentive.
The permanent extension and expansion of the special rules for deductions of conservation easements without any associated reforms is harder to understand, given the many administrative difficulties and abuses associated with this provision of the tax Code. (For commentary, see Halperin, McLaughlin, Colinvaux).
So although there may be merit in the margins to some provisions, as a whole, the case for the legislation without offsets is rather underwhelming. If there were offsets, then at least the trade-offs could be more directly assessed.
In short, although it is obvious that the America Gives More Act is not intended as a tax reform measure but rather reflects legislative business as usual, nonetheless it is disappointing to see more give-aways without much if any consideration of who should pay, and whether the give-aways are really worth it. But without an offset, there is little electoral cost to voting in favor of legislation, especially charitable giving legislation, which is always easy to frame, without much analysis, as helping those in need.
Roger Colinvaux
July 19, 2014 in Current Affairs, Federal – Legislative | Permalink | Comments (0) | TrackBack (0)
Wednesday, July 16, 2014
Notes on the CPI Report on the IRS Targeting Scandal
The Center for Public Integrity has released an investigative report about the IRS Tea Party targeting scandal, in which the CPI reviewed thousands of pages of documents and interviewed dozens of insiders. The report provides a good high-level overview of the scandal, and makes a few useful findings about the Exempt Organization function within the IRS. To many, the findings may come as no surprise, but bear repeating: over time the IRS has fewer employees to regulate a rapidly growing sector, the already low rate at which the IRS investigates exempt organizations is shrinking, the social welfare category (i.e., the one at the heart of the targeting scandal) is growing, and the IRS is increasingly timid – backing down to political pressure. Unfortunately, none of this makes for an effective overseer of a vital part of civil society.
Although the report is useful, some peripheral statements should be more closely considered if only because a number of misconceptions about the IRS targeting scandal continue inadvertently to be spread. One statement in the report is that "It wasn't until the Supreme Court's Citizens United v. Federal Election Commission decision in 2010, however, that politically active nonprofits — social welfare groups as well as 501(c)(5) labor unions and 501(c)(6) trade groups — became a major force in political elections, all while receiving a de facto tax subsidy." The implication from the "de facto tax subsidy" language is that political activity, when conducted after Citizens United by a noncharitable tax-exempt like a 501(c)(4), (5), or (6), gets an unwarranted subsidy and is abusive. But this is not really right. Political activity by a noncharitable exempt generally is not tax-advantaged relative to the same activity by a political organization (aka a "527"). Rather, political activity by a noncharitable exempt actually triggers a tax that is intended to make the tax treatment of political activity consistent across sections of the tax code. There is no abusive subsidy for political activity here.
Later, the report notes that "Social welfare and other nonprofit groups galloped into the post-Citizens United era with an inherent advantage over overtly political groups: They could hide the source of their funding, regardless of whether those sources were corporations, individuals or other special interests. And they're only required tell the FEC the names of donors who give money to help produce specific ads — something that rarely happens." This point bears more than passing emphasis. The anonymity offered to donors by noncharitable exempt status, and not a tax subsidy, is the underlying legal issue at the heart of the targeting scandal post-Citizens United. In other words, the targeting scandal is not really about taxes at all, it is about donor disclosure or the lack thereof.
The report says that: "The tea party affair has directed attention away from what many IRS workers say is the much larger problem — regulating the activities of politically charged nonprofits." and also that the IRS is "supposed to ensure 501(c) nonprofit organizations don't become more political than the law allows." The broad meaning here is right: the targeting scandal has diverted attention from some real problems with the legal architecture. Also, the IRS does have a legitimate role to play when it comes to political activity and tax exemption. But these statements unintentionally play into another misconception about the IRS's role when it comes to the political activity of noncharitable exempts and political organizations. In this context, the IRS does not really "regulate" political activity in the sense of deciding whether or not the activity is permitted. Rather, the IRS's function is to classify organizations based on their purpose as measured by the quantum of their activities. This is an important distinction. The IRS does not regulate speech or activity as such; rather, the IRS, as charged by Congress, assesses organization purposes and activities and applies a tax label ((c)(4), 527, etc.). So political activity is relevant to tax classification, but it is not a question of permitting or prohibiting political activity.
The report also states that "Political '527 groups' are tax exempt like 501(c)(4) groups, but unlike them, they must disclose their donors." It should be noted that the point about disclosure is correct, but not the point about tax-exemption. Broadly, 527 groups are taxed on their investment income whereas 501(c)(4)s and other noncharitable exempts are not. So the tax treatment is not equivalent. But as noted earlier, if a noncharitable exempt engages in political activity, then a tax is triggered, which is intended to make the organizational tax treatment of political activity broadly uniform across exemption categories.
But none of this undermines the key thrust of the report's message -- that the regulatory environment of the IRS exempt organization function is in crisis and in need of constructive solutions.
Roger Colinvaux
July 16, 2014 in Current Affairs, Federal – Executive, Federal – Legislative, Studies and Reports | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 15, 2014
U.S. House to Consider Charitable Giving Legislation
The House of Representatives this week is likely to take up charitable giving legislation. Last week, the Rules Committee reported out H.R. 4619, which modifies and expands on a charitable giving bill of the same number marked up by the Ways and Means Committee on May 29. Committee Report here.
Renamed the "America Gives More Act of 2014," H.R. 4619 combines several separate charitable giving measures. The charitable giving incentives of H.R. 4619 now are:
- Food Donations. Make the special enhanced deduction for charitable contributions of food inventory permanent and modify this enhanced deduction to: increase the percentage limitation from ten to fifteen percent for business taxpayers, provide for a special deemed basis rule for certain taxpayers, and permit fair market value of donated food to be determined disregarding the fact that there may not be a market for the food, among other special valuation rules. (This provision applies retroactively to restore this expired deduction.)
- IRA Distributions to Charity. Make permanent the exclusion for distributions from individual retirement arrangements to certain public charities. (This provision applies retroactively to restore this expired exclusion.)
- Conservation Easements. Make permanent the special percentage limitations and carryforwards for charitable donations of conservation easements, and extend such favorable treatment to contributions by certain Native Corporations, as defined under the Alaska Native Claims Settlement Act. (This provision applies retroactively to restore this expired deduction.)
- Extend Time to Claim. Generally allow taxpayers until the tax-filing deadline (April 15) to claim charitable deductions for the tax year.
- Reduce Foundation Excise Tax on Investment Income. Replace the two rates of tax on the investment income of private foundations with a single flat rate of one percent.
These provisions are broadly consistent with provisions in the "Tax Reform Act of 2014," a discussion draft released by Ways and Means Committee Chairman Dave Camp in February, with some notable exceptions. For instance, the Tax Reform Act:
- Eliminates the special enhanced deduction for food inventory rather than retaining and expanding it.
- Does not include the IRA distribution exclusion, i.e., allows it to expire.
- Does not expand the special rules for donations of conservation easements to new donor categories, and provides for a modest reform that no deduction is allowed for easements relating to golf courses, a proposal also advocated by the Treasury Department (page 95).
Whether the differences between H.R. 4619 and the Tax Reform Act reflect a change in position (and a move away from reform) or reflect the fact that H.R. 4619 is not primarily a tax reform measure remain to be seen.
Roger Colinvaux
July 15, 2014 in Current Affairs, Federal – Legislative | Permalink | Comments (1) | TrackBack (0)


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Actionable Books"
March 26, 2012 8:10 PM
Marketing Philosophy (It's Squiggly Too) tagged "Actionable Books"
This is how I think... or, rather, how I'm thinking about things today. I'm a big fan Chris Taylor over at Actionable Books. He does some of the best and most interesting in-depth conversations with some of the business world's... Read more

subset: commoncrawl


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One of Talkeetna's own has achieved a lifelong dream, and published a new book. Ellen Thea's first-ever published book is called "On My Way to the Apocalypse," and she'll be reading from it at a book release party at the Talkeetna library on Friday night.
The book is a prose poem with pictures, and follows a fanciful story of transcendental accidents, each turn of the page reveals a new twist to the poem, an adventure of apocalyptic scale.
Ellen says the book is a reflection of her own attempts to stay upbeat despite the undeniable face that the universe tends towards entropy.
Thea is a Talkeetna resident and KTNA volunteer, and she's loved words and writing for her whole life.
Ellen will be reading from her book on Friday evening at the Library. She recorded a selection for us to play on KTNA an excerpt, if you will, about the journey through the apocalypse and out the other side.
You can hear more of Ellen Thea's book "On My Way to the Apocalypse" at the release party and reading on Friday night at the Library, starting at 6.


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Pastoral Ministries
Rev. Laird Borst is a graduate of Concordia University College of Alberta (BA) and the Lutheran Theological Seminary in Saskatoon (M.Div.), and is ready to help members and non–members in areas of personal, spiritual, and marital growth. The various pastoral acts of the church (e.g. baptisms, weddings, and funerals) are available upon request.
Sunday School
Thanks to many willing volunteers, Sunday School will resume on September 7. Class will be from 10:00-10:45 AM. The "teacher of the day" will also be available to care for children during the sermon.
Confirmation studies are designed to help youth and adults understand and affirm their baptism and Christian faith. Contact Pastor Laird to enrol.
Book Study
The Book Study will be offered again starting Monday noon hour, September 15. If you have a book you would love to read and study, please talk to Pastor Laird.
Potluck and Bible Study
Adults are invited on the 3rd Saturday of each month (beginning in September) for Potluck Supper at 4:30pm and then Bible study from 5:30 – 6:30pm. (Childcare is provided .) Participants do not need to be members of Hope or even currently involved in a church community. We will be using the Serendipity Bible for our studies and this year we will focus on whol-i-ness, spending time discussing passages from the Bible that center around our spiritual, physical, vocational, emotional, relational, and volitional lives. Each study will address a separate topic so if your schedule doesn't allow you to attend every week, no problem!
Women's Ministry
Women meet at 1:30 p.m. on the second Wednesday of every month for bible study and on the last Tuesday of the month, from 9-3 for quilting and fellowship. All women are welcome.
Men's Breakfast and Bible Study
The men are invited for a time of fellowship and bible study at 8:00 am on the second Saturday of the month. They meet at the A&W on 50 Street and 101 Avenue.
"Delight yourself in the LORD and he will give you the desires of your heart."
Psalm 37:4


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[MLS] Dominican Republic native Birnis Adames, who started playing soccer only four years ago, won the Sueno MLS 2011,
the league's talent contest, and will receive an invitation to join one of Philadelphia Union's academy teams.
Adames, 18, was one of the national finalists among 15 field players, who emerged from the 1,200 players who participated in regional tryouts in Dallas, Chicago and Philadelphia.
Anthony Hall from Dallas was named the "Good Hands" top goalkeeper ("El Portero Allstate") in competition with the other two national finalists.
The finalists gathered on Wednesday in Dallas for four days of intense pro-style training sessions and scrimmages against the FC Dallas under-16 and under-18 teams.
Major League Soccer Technical Director Alfonso Mondelo coached the players.
"Birnis Adames showed a lot of consistency over the four days in Dallas," said Mondelo. "He is a player who took advantage of the opportunities he had. He scored four goals in two games and showed he is up for big challenges. Adames is very fast and crafty, has good height and he's got nose for the goal, plus he became an instant leader who quickly organized the group and joined them together."
Adames' older brother, Chanel, played for the Dominican Republic U-17 national team and was a key factor in Birnis' decision to change his focus from baseball to soccer.


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X (Adventures)
|Eye color
|Hair color
|Vaniville Town
|Trainer class
|Game counterpart
(Japanese: エックス X) is a main character in the manga series Pokémon Adventures.
X is a former Pokémon Trainer who was shown to be very strong, even as a small child. However, the pressure he got from the paparazzi eventually got to him, which caused him to become a shut-in who refuses to leave his house despite his friends' protests.
|Spoiler warning: this article may contain major plot or ending details.
X is first seen winning a Kalos Junior Tournament as a small child. While his friends come to celebrate his victory, they are immediately crowded on by the press, who ask if X will become a Gym Leader or even an Elite Four member. Years later, X has become a shut-in and refuses to leave his room. Despite his friends' daily efforts to get him outside, he refuses because of his fear of having the public's eye on him.
Suddenly, the Legendary Pokémon Xerneas and Yveltal appear and begin destroying Vaniville Town in their clash against each other. Y tries to warn X about what is going on, but he refuses to listen to her because the reporters Alexa and Viola are outside recording the commotion.
X is soon attacked by Team Flare, who are after the Mega Ring on his wrist. Y and Garu try to save X, only to be easily swatted away. Suddenly, Kogaru reacts to X's Mega Ring, which allows her to evolve into Mega Kangaskhan and easily defeat the villains, forcing them to retreat. After Xerneas and Yveltal had left, the five group together in the ruins of their destroyed town. They decide that with their homes gone and certain things they need to accomplish, they all need to head off. Although X does not want to go, Y tells him that he has no choice now that he's homeless. Y forces X into a new change of clothes and has him sleep in a tent on her Rhyhorn since he refuses to move otherwise. With that, the five friends set off together.
After arriving in Aquacorde Town, the others stay at an inn while X sleeps outside in the tent. Unbeknownst to them, the inn was actually a trap set up by Team Flare, which led to Y, Trevor, Shauna, and Tierno being trapped inside while Aliana and Mable attempt to capture Kogaru when X isn't looking. Y manages to escape and informs X of what is happening to Kogaru. Angered, X attempts to have Kogaru Mega Evolve again, only for it to fail. Instead, X uses Chespin to battle Team Flare, and succeeds in rescuing Kogaru, defeating Aliana and Mable, and rescuing the rest of X's friends from the inn.
The group soon arrives in Santalune City, where they meet up with Viola again. Viola reveals that she is the Santalune Gym Leader and offers to help the group by offering sanctuary at her Gym. Although Y said to not trust adults, the group decides to trust Viola's word, which angers Shauna into running away for going against what they said earlier. Later, X battles Viola at the Gym while Y, Trevor, and Tierno investigate the photos Viola took at Vaniville Town. There, X reveals where he obtained his Mega Ring.
They are soon attacked by Celosia of Team Flare, who had Shauna possessed by a Honedge and kept under her control. Celosia uses Shauna to steal Garu's Kangaskhanite and knocks Viola unconscious. Celosia attempts to escape, forcing X to pursue her. As he chases her down, X is approached by Korrina, who has her Lucario Mega Evolve.
On hand
| Garu
Garu (Japanese: ガル Garu), the mother Kangaskhan, and Kogaru (Japanese: コガル Kogaru), the child Kangaskhan, are X's only known Pokémon. X has had the two of them since childhood, where he used them to win a Junior Tournament, getting him the eye of the paparazzi. After becoming a shut-in, X began neglecting the two, which forced Tierno to feed them in his stead. X's refusal to leave his house had a negative effect on Kogaru, causing her to imitate her Trainer and refuse to leave her mother's pouch despite being well over three years old. With X's Mega Ring, Kogaru can Mega Evolve into a Mega Kangaskhan.
|X & Y chapter
|X's Chespin
| Chespin was given to Trevor from Professor Sycamore alongside Froakie and Fennekin in the hopes that they would break X out of his depression. Although Tierno stated that one of the starters should go to X and Y, X refused to let Chespin go on his team despite using it to battle against Team Flare.
Chespin's only known move is Pin Missile.
|X & Y chapter
|From Pokémon X.
|Pokémon Adventures main characters
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quotes on daddys princess Quotes & Sayings
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Start at the entrance to the mall office. Pace counterclockwise, with faster walkers drifting to the middle and the slower ones staying on the outskirts of the path. And don't disrupt the flow.
As in most group activities, there are understood rules and etiquette involved with what has become a great form of exercise and even a hobby for many. Mall walking has grown tremendously over the past couple of decades, with the public realizing the great atmosphere of walking on an indoor course with the added benefits of window-browsing and making new friends.
The Heart Walkers program was started at Hickory Point Mall in 2000 as a partnership between the mall and Decatur Memorial Hospital, said Candy Carroll, marketing coordinator of Hickory Point Mall.
Anyone Can Do It
The program, open to anyone at no cost, allows participants to log in their miles, either by hand or at the DMH kiosk, as they walk through the mall's course for better health and to obtain prizes at various milestones.
"It's grown quite a bit; we see a lot of people who are becoming more heart healthy, and we've seen an increase in the middle-age group and also have a lot of younger ones," Carroll said. "We also see a lot of people recovering from knee surgery or hip surgery. It's very popular because it can be done at any time."
The mall's doors open at 6 a.m. and close at 10 p.m., and Carroll said the periods of time in the early morning and in the early evening attract the most walkers. The mall is a good atmosphere to exercise because it provides shelter from the weather and has a surface conducive to walking.
"It has a very even surface. You don't have to worry about potholes or twigs," Carroll said. "You can do it in any type of weather; the temperature is cool in the summer, and in the winter, when you have to stop exercising outside, you can come in here because it's warmer."
Donna Whitacer and Shirley Munjoy said they have been coming to the mall together for the past couple of years. The two women have met a lot of people while walking, Munjoy said.
"It's a good atmosphere," Whitacer said. "(Walking) makes you feel good; we can walk in the winter and the summer and be out of the weather."
Whitacer and Munjoy said they usually take about 45 minutes to complete three laps around the mall. One lap, including the nooks, is equal to about two-thirds of a mile, or 1 kilometer. Just walking lengthwise, from J.C. Penney to Bergner's is closer to a half mile, Carroll said.
Walking is an excellent form of exercise, and even those with health problems such as arthritis can walk because it's easy on the joints, said Dr. Tim Miller, medical director of the DMH Wellness Center. Walking can help lower blood pressure and blood sugar, improve cholesterol levels and help maintain or lose weight, he said.
A Great Social Activity
"There is a lot in the way of medications to treat diseases, but if you think about regular exercise and the impact it has on those illnesses, you can do as much or even more with an exercise program," Miller said. "The group environment (through walking at the mall) adds to it; you're able to develop relationships with others out there walking and depend upon that support."
Charles Bell is a 14-year veteran of the mall walking scene and typically comes out to the mall about six days a week.
"I've met a lot of people I never thought I would meet before; they're all very nice, really," he said. "We all have about the same thing in common, for one reason or another. Most of us (walk) for health reasons."
Many, if not most, of the walkers have been coming for years, Carroll said, and several of the food shops open early to serve coffee to the walkers.
Jerry Schmidt and Doris Turner, who have been mall walking since 1993, said they usually pace around a couple of times with a group of friends before sitting down to a cup of coffee to visit.
"We have a bunch that walks around together, and we like to come in the wintertime," Schmidt said. "It gets me up and gets me going."
Courtney Klemm can be reached at email@example.com or 421-6968.
To see more of Herald & Review, or to subscribe to the newspaper, go to http://www.herald-review.com.
Copyright (c) 2007, Herald & Review, Decatur, Ill.
Distributed by McClatchy-Tribune Information Services.
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yesterday i bought new sensation xe with latest ics update. Hboot v 1.27
Is there any way to root my phone?
or how can i downgrade Hboot verson?(1.27 is not included in revolutionary.io)
or is there any way to go back to GB to root?
plz help.
so sad. I have seen devs are making sense 4 roms. but still I have nothing to do...
does any one know when I can root???
hey can I use HTC super tool to root my sensation xe with hboot 1.27??
I heard of this...it contains tacoroot which is a temporary root but I heard its unstable and it only gives root access in adb..shell which wont be helpful in your case
sent from my blazing fast pyramid through sonic waves
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HARTLEPOOL and East Durham will be hit by gales this weekend, according to weather experts.
The Met Office is forecasting strong winds across the North East on Sunday and overnight into Monday morning.
A Met Office spokesman said: "Gales are likely to develop around exposed coastal areas of northern Britain.
"Very strong inland gusts are also expected, particularly in association with heavy showers.
"The public should be aware of possible minor disruption, particularly to transport."
Saturday is expected to see some bright spells but with the risk of the odd shower.
Temperatures should stay in the mid-teens throughout most of the weekend before dropping when the strong winds arrive on Sunday afternoon.


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Haniyeh Aide: Any Future Israel-PA Accord Depends on Hamas
Advisor to former PA premier slams U.S. exclusion of Hamas from talks, says peace deal highly unlikely.
Israel and the Palestinian Authority will never succeed in implementing a permanent political agreement, unless Hamas decides to approve it, adviser to former prime minister and Hamas leader Ismail Haniyah Wednesday told Haaretz.
The adviser, Ahmed Yusef, went on to say that the negotiations between the U.S. and Palestinian Authority Chairman Mahmoud Abbas hinged on future negotiations between Hamas and Abbas' Fatah. The two rival organizations severed all connections following Hamas' violent seizure of power in the Gaza Strip last June. "Abbas' talks with the U.S. will continue to be no more than 'photo-ops' for as long as Hamas is not involved in the talks," said Yusef.
The adviser indicated Hamas would be willing to engage in a dialogue with the U.S. on any subject Washington desires. "We have no problems discussing issues with the United States or with the Europeans," he said. "There are European officials who are willing to act as mediators, but the Americans are closing all the doors."
In any case, Yusef stressed, the U.S. is wrong to pursue negotiations with Abbas alone, without incorporating Hamas in the talks. "I think the Americans must explore the alternative Palestinian channel, which is Hamas," he said. "They should find out for themselves what our organization stands for. If they choose not to do so, and go ahead with talks without including Hamas, then they must realize that Abbas would ultimately require Hamas' approval for implementing agreements."
Yusef added that any agreement Abbas might eventually sign with Israel will need to be approved either by a national Palestinian referendum, or in a general election. "No such event will take place, unless Hamas authorizes it," he explained. "Hamas is an important regional player and it will continue to be a cardinal player in any sort of political agreement between Israel and the Palestinians."
Yusef also said the Hamas would not agree to engage in diplomatic talks with Israel. "That's what Abbas is concerned with - reaching a permanent agreement with Israel. In reality, he has virtually no chance of achieving his goal, because Israel is not prepared to make significant concessions for the formation of a Palestinian state, and the United States is unwilling to pressure Israel into making these concessions."
Yusef was equally pessimistic about the prospects of the international peace conference that U.S. President George W. Bush announced he was planning for sometime this fall. "This summit has virtually no chance of getting off the ground. It represents nothing more than Washington's desire to secure an achievement in the Israeli-Palestinian sphere, to make up for its failures in Iraq."
Hamas' spokesman in the Gaza Strip, Fauzi Barhoum, echoed Yusef's statements by telling Haaretz that Abbas did not enjoy a sufficient mandate to determine the future of the Palestinian people without consulting Hamas. "Any agreement will necessitate the approval of Parliament, which is dominated by Hamas. First, Abbas will have to renew the dialogue with Hamas and achieve national unity. Only then will we be able to negotiate with foreign powers. Abbas must accept not only Hamas' position, but reach a middle ground with all other groups and organizations."
U.S. Secretary of State Condoleezza Rice, who is visiting Israel as part of her Middle East tour, is slated to meet with Abbas Thursday in the West Bank city of Ramallah.
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ECCO Urban Lifestyle
Product Reference: 83060456929 Colour: Camel / Cocoa Brown
A rugged, lace-up style which is a great-looking casual shoe with hidden extras, such as GORE-TEX 100% Waterproof construction and Receptor technology (for grip and full-length foot support, even over tricky terrain), making this a great choice for everyday wear, with the versatility to comfortably wear offroad.
- 5 eyelet Derby lace-up, casual shoe
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- Textile lining is softly padded and highly breathable
- Textile-covered, removable PU inlay sole for lasting softness and increased air flow
- Direct-injected, Polyurethane (PU) midsole for shock absorption, cushioning and flexibility
- Full-length RECEPTOR technology for support and stability during walking, even over rough terrain
- Rubber Sole for grip, traction and durability
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Tag: flux
Posted on October 11, 2016
Useful Developer Tools #4: f.lux
It is no secret, that most developers are nocturnal. That's why there are many tools that makes a coder's nightlife easier. Dark Mode in IDEs is a good example. But did you know f.lux? This tiny tool makes the color of… Read More


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AVS Video Converter v220.127.116.115-Cracked-CHAOS
- Type:
- Applications > Windows
- Files:
- 7
- Size:
- 82.05 MiB (86035975 Bytes)
- Uploaded:
- By:
- Anacondaz
- Seeders:
- 1
- Leechers:
- 0
- Comments
- 8
- Info Hash:
(Problems with magnets links are fixed by upgrading your torrent client!)
AVS Video Converter v220.127.116.115 AVS Video Converter can help you handle conversion work very easily and flawlessly. Encode HD Video (inc. AVCHD, TS, TOD, AVI HD, M2TS, etc.), AVI, MP4, WMV, Blu-ray, 3GP, DVD, VOB, MPEG, H.263/H.264 codecs, DVR-MS, MKV, FLV, etc. with AVS Video Converter . Install Notes: 1-) Unpack & Install the program. 2-) Copy what's included in crack folder into program folder where the program is located. 3-) Run the program and Enjoy it full! virus total result for the crack https://www.virustotal.com/file/caf72212764bfe00bd48a3b00091f30c0aecddd421e5e25afb12f99d16447e13/analysis/1338679541/ ----------------------------------------------------------------------------------- ----------------------------------------------------------------------------------- To know , learn and get all things come and join here LOTS AND LOTS OF GREAT THINGS ARE HERE https://forum.suprbay.org For reporting bad or suspicious torrents https://forum.suprbay.org/forumdisplay.php?fid=29 For my 1600+ Torrents http://thepiratebay.se/user/Anacondaz/ credit to the original creator encoder
stops at 78.7%
had power problem
now seeding full speed
sorry for the delay
now seeding full speed
sorry for the delay
Thanks! Can this be updated or will doing so disable the program?
Keep getting EAccess Violation
won't let me select dvd
u guys r great ,
it takes a lot of good stuff in the soul to give,
you r giving it for free
it takes a lot of good stuff in the soul to give,
you r giving it for free
Thank you for this program, seems to work well.
Took about five minutes to download.
From what I can tell the program works well.
Thanks for the great torrent Anacondaz.
From what I can tell the program works well.
Thanks for the great torrent Anacondaz.


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