Category: Uncategorized

IRS REINSTATES GROUP EXEMPTION LETTER PROCESS

On January 15, 2026, the IRS released two documents, Notice 2026-8 and Revenue Proc. 2026-8, which provide updated guidance regarding group tax exemption letters and removes the moratorium the IRS administratively imposed in 2020 on new group exemption rulings. Additionally, the two documents affect organizations with current group exemption letters who generally have one year […]

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CORPORATE TRANSPARENCY ACT –NOW EFFECTIVE – January 2024 (updated)

This memorandum will be updated periodically as developments warrant. Updated March 24, 2025 In an interim final rule released on March 21st, FinCEN revised the definition of “reporting company” to mean only those entities formed under a foreign country’s law and registered to do business in any US State. This has significantly reduced the universe […]

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IMMIGRATION ENFORCEMENT ALERT

The start of the second Trump administration is likely to see a renewed emphasis on immigration enforcement in the workplace. Estimates of the number of undocumented immigrants in the United States vary from 11 million to 20 million. In metropolitan areas, the concern is possible inspections by ICE (U.S. Immigration and Customs Enforcement) especially relating […]

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SCHOOL ALERT – ANNUAL CERTIFICATION OF RACIAL NON-DISCRIMINATION

Organizations which operate a school1 even if they are not required to file Form 990 or Form 990 E-Z must annually publish a public notice of non-discrimination in a newspaper of general circulation and file “Form 5578- Annual Certification of Racial Non-Discrimination” with the Internal Revenue Service. The suggested language for such notice is as […]

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A PRIVATE FOUNDATION PRIMER

This memorandum will attempt to outline certain reporting and compliance obligations relating to private foundations. You should also review a booklet which you may have received from the Internal Revenue Service entitled “Compliance Guide For 501(c)(3) Private Foundations” (Publication 4221PF) (available at www.irs.gov). IRS Reporting and Filing Requirements State Filings Treatment of Contributions Fiduciary Duty […]

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THE FUTURE OF LIMITED LIABILITY COMPANIES AS SECTION 501(c)(3) ENTITIES

To date, the Internal Revenue Service (IRS) has generally not processed applications by limited liability companies (LLC) for recognition as a tax-exempt entity under Section 501(c)(3) of the Internal Revenue Code.  The last IRS guidance on this topic was nonbinding and was issued 20 years ago, shortly after LLCs emerged as a new form of […]

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APPRAISAL REQUIREMENTS FOR DONATIONS OF REAL PROPERTY AND OTHER ASSETS TO SECTION 501 ( C ) (3) ORGANIZATIONS REVISED 2025

Introduction For Federal tax purposes, you must file  Form 8283 to report information about noncash charitable contributions for which you are claiming an income tax deduction .. You must file one or more Forms 8283 if the amount of your deduction for each noncash contribution is more than $500. You must also file Form 8283 […]

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WHISTLEBLOWER RIGHTS AND NEW YORK NON PROFITS

Section 715-b of the New York Not-for-Profit Corporation Law (the “NPCL”) requires nonprofits with 20 or more employees and annual revenues in excess of one million dollars to adopt an explicit whistleblower policy to protect from retaliation persons who report suspected improper conduct. Nonprofits with fewer than 20 employees or with annual revenues lower than […]

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NON PROFITS- WHERE TO INCORPORATE- NEW YORK OR DELAWARE?

Nonprofits operating in New York or planning to operate in New York frequently assume that they have no choice but to incorporate in New York State. However, New York is not the only option. Delaware is becoming an increasingly popular choice for nonprofits because of the potentially friendlier legal regime. It should be noted that […]

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RULE 144: SEC PROPOSES CHANGES FOR MARKET ADJUSTABLE SECURITIES

In late 2020 , the SEC proposed or adopted a number of regulatory initiatives which benefit the issuers and other participants in private placements. These include an expansion of the definition of “accredited Investor” under Regulation D, expanded eligibility and simplification of the rules regulating private placements and an exemption permitting the compensation of “finders” […]

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