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June 23, 2020 - ​512(a)(6) and Other Comments Project Update

06/23/2020 10:36 AM | Deleted user

We are pleased to announce that on June 23, 2020, the TEGE Exempt Organizations Council submitted comments to the IRS and Treasury in response to proposed regulations under Section 512(a)(6), commonly known as the UBIT Silo regulations. The comments were 101 pages, with exhibits, and represent a herculean effort on the part of the group below to spot issues, identify potential solutions, propose examples, and collaborate, coordinate, draft, and edit—all within the short window of time to submit comments for official consideration. Thanks to the committee for the generous gift of time, thought, and leadership. Thanks also to Alexander L. Reid (Regulatory Affairs Chair) and Chelsea Rubin for their leadership.

  • Dayo Adesuyi
  • Farah Ansari
  • Ted R. Batso, Jr.
  • Lori Boyce
  • Amy Ciminello
  • Stephen M. Clarke
  • Nathan M. Doane
  • Mallory Fairless
  • Polly Federico
  • Sara Elizabeth J. Hyre
  • Ed Jennings
  • David Lowenthal
  • Elizabeth Mills
  • Christopher N. Moran
  • Sarah-Jane Morin
  • Megan M. Okun
  • Jennifer Richter
  • Emmett H. Robertson
  • Mary Torretta

As always, we have added access to the comments on the Council’s website under Announcements/Comments. Per Council policy, the comments include a note that comments do not represent the views of the TEGE Exempt Organizations Council or any particular Council member.

Section 4960 Project. The Comments Committee is seeking volunteers to participate in a comments project related to the Section 4960 Executive Compensation Excise Tax. Please email Alex Reid ( if you are interested.

Forms & Instructions Project. The Comments Committee is interested in maintaining engagement with the IRS on the forms and Instructions applicable to tax-exempt organizations, particularly the Form 990 series and Form 4720. Ideally, the Committee would like to collect comments over the course of the filing season on the prior year’s forms and make an annual submission of comments to the IRS. We have added a submission form on the Council website at Alternatively, you may email Eve Borenstein ( and Lori Boyce (

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