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  • September 25, 2018 - ​Feedback Requested by IRS and Chief Council – Seeking Volunteers for Comment Process

September 25, 2018 - ​Feedback Requested by IRS and Chief Council – Seeking Volunteers for Comment Process

09/25/2018 11:06 AM | Deleted user

TEGE EO Council Members and Alumnae, Past Attendees, Tax Press, and Friends,

At the September 11 TEGE Exempt Organizations Council program, government speakers Margaret Von Lienen, Elinor Ramey, and Janine Cook asked for comments/feedback on a variety of topics. We are seeking volunteers to participate in one or more comment topics below and to actively and timely participate in providing feedback/perspective. The forms/instructions comments in particular are needed quickly in order to be relevant.

  • Forms/instructions’ immediate needs related to tax reform – 990 series, 4720N, and K-1s (including Form 990-T when released);
  • Unrelated Business Income Tax, including 512(a)(6) silo rules, Notice 2018-67, NOL ordering rules, investment revenue issues, and use of NAICS codes for identifying separate trade or business activities;
  • Clarification as to when disclosure of related organization as a “controlled entity” under 512(b)(13) is required on Form 990 Schedule R, Parts II and IV;
  • Partnership audit rules as they relate to exempt organizations; and
  • Section 4968(c) (excise tax on investment income of private colleges and universities) guidance needed and transitional relief,

Please respond to Danika Mendrygal ( as soon as possible if you are interested in actively contributing to the comment process, or if you have existing written comments to submit.

We are also seeking redacted sample portions of partnership agreements that address the partnership audit rules with respect to exempt organization participation and the allocation of any liability for tax at the partnership or partner level. Please forward these to Danika ( as well.

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