IRS priority guidance plan—Exempt organization projects | KPMG | GLOBAL
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IRS priority guidance plan 2016-2017—Exempt organization projects

IRS priority guidance plan—Exempt organization projects

The priority guidance plan for 2016-2017 includes a list of projects that the IRS and Treasury Department intend to work on during the 12-month period ending June 30, 2017, with projects relating to tax law issues in all areas, ranging from consolidated returns to tax administration.


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The exempt organization guidance projects included in the 2016-2017 priority guidance plan [PDF 160 KB] are summarized below.

Projects under the heading “Exempt Organizations”

  • Revenue procedures updating grantor and contributor reliance criteria under sections 170 and 509
  • A revenue procedure to update Rev. Proc. 2011-33 for “EO Select Check”
  • Final regulations under sections 501(a), 501(c)(3), and 508 relating to Form 1023-EZ, Streamlined Application for Recognition of Exemption under Section 501(c)(3)—Note that final and temporary regulations were published on July 2, 2014
  • Update Rev. Rul. 67-390 (requiring that tax-exempt organizations that undergo legal structural changes to reapply for tax-exempt status)
  • Regulations and other guidance on section 506 (requiring section 501(c)(4) organizations to provide notice to the IRS)—Note that final and temporary regulations were published on July 12, 2016, and Rev. Proc. 2016-41 was published on July 25, 2016
  • Final regulations on section 509(a)(3) supporting organizations—Note that proposed regulations were published on February 19, 2016
  • Guidance under section 512 regarding methods of allocating expenses relating to dual-use facilities
  • Final regulations under section 529A on Qualified ABLE Programs—Note that proposed regulations were published on June 22, 2015
  • Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners
  • Update to Rev. Proc. 92-94 (regarding the equivalency determination process for purposes of sections 4942 and 4945) 
  • Guidance regarding the excise taxes on donor advised funds and fund management
  • Guidance under section 6033 relating to the reporting of contributions
  • Final regulations under section 6104(c) (note that proposed regulations were published on March 15, 2011)
  • Final regulations under section 7611 relating to church tax inquiries and examinations—Note that proposed regulations were published on August 5, 2009

Treasury has suspended its project to issue proposed regulations under section 501(c), relating to political campaign intervention. Congress has denied appropriations for such purpose.

The priority guidance plan also includes projects relating to regulations concerning the fractions rule under section 514(c)(9) and to final regulations under section 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations described in section 501(c)(9)—note that proposed regulations were published on February 6, 2014.

Projects relating to charitable contributions

  • Final regulations under section 170 regarding charitable contributions—note that proposed regulations were published August 7, 2008
  • Guidance under section 170(e)(3) regarding charitable contributions of inventory
  • Guidance under section 170 regarding charitable contributions of appropriative water rights
  • Guidance under section 170 regarding charitable contributions of conservation easements

Projects relating to tax-exempt bonds

  • A revenue procedure that will update Rev. Proc. 97-13 relating to the conditions under which a management contract does not result in private business use under section 141

Other projects

Among other projects of interest to exempt organizations are, for example:

  • Projects involving employee benefits
  • A project involving regulations under section 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government
  • Guidance under section 6050S relating to Form 1098-T, Tuition Statement
  • A project related to the U.S. Supreme Court’s decision with respect to the recognition of same-sex marriages


For more information, contact the Managing Director-in-Charge of KPMG's Washington National Tax Exempt Organizations Tax group:

D. Greg Goller | +1 (703) 286-8391 |

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