Looking for oral exchange

Added: Tessica Brickhouse - Date: 24.02.2022 01:43 - Views: 29313 - Clicks: 5150

I wrote Lois Lerner asking four brief questions about how to reconcile Revenue Rulings and , distinguishing tax-exempt issue advocacy from political intervention during elections, and requesting a General Information Letter to clear up any perceived discrepancies between them. My letter, and the key language of the rulings, is posted here. Issue during elections:. We have two revenue rulings—one from , that applies to the f tax, provides multiple factors. Another one, , applies to the c 3 prohibition. And the question seems to be, biggest question is for c 4 organizations trying to meet a primary purpose test, what test do they use?

So what you need to be looking at is their social welfare activity and what fits neatly into that box and what might not fit neatly into that box. Wait, what? There are no safe harbors in these multi-factor tests, unless perhaps you have all the listed factors in your favor. As Janine pointed out we tried not to do the bookends in that one.

The two rulings do address scenarios in the middle, gray area, where there is a mix of good and bad factors. She missed the point. In between those times, they are reluctant more so now than in the past, in my experience to explain what they mean. You have to reasonably try to comply with the law. In each one, it says all the facts and circumstances. And while each of them lay out some specific facts and circumstances, and do an application of law to facts specific and list some specific factors, the test is ALL. OK, so it seems what Ruth is adding is that each test goes beyond the specific factors listed and may involve unlisted factors.

The community was very, very complimentary to the IRS that we had laid out our thinking process. Yes, it was a step forward when the rulings came out, though still puzzling why they were worded differently. The stakes are very high. But do they disagree with it? This was a slow-pitch softball question, right over the plate. I call strike. All the more reason why the IRS should issue a written General Information Letter in response to my August 24 request to clear up the uncertainty.

By the way, the Congressional Research Service recently looked at the two rulings and concluded from the examples that they mean to say the same thing, in a report issued August 29, Whether we get a precise answer or not, you can see where the IRS is heading. Do not confine your advice to the factors that appear in only one ruling, such as the seven factors in the ruling. For instance, geographical targeting appears in the ruling but not in the version. And if you blast out an to your nationwide list, not targeted to any specific location, that should work in your favor.

To those who care about reforming the political tax rules, to reduce vagueness, ambiguity, unpredictability, excessive caution, and abuse, I would say:. We need bright lines for tax-exempt political speech, and real safe harbors. If that promise is timely and sincere, the topic should be in their Priority Guidance Plan. For more on this debate, see here. Readers should consult counsel of their own choosing to discuss how these matters relate to their individual circumstances.

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Download Blog Post. Author: Gregory L. I think you know my question— I wrote Lois Lerner asking four brief questions about how to reconcile Revenue Rulings and , distinguishing tax-exempt issue advocacy from political intervention during elections, and requesting a General Information Letter to clear up any perceived discrepancies between them. Issue during elections: We have two revenue rulings—one from , that applies to the f tax, provides multiple factors. To Lois and Ruth, I would say: This was a slow-pitch softball question, right over the plate.

To political tax law practitioners, I would say: Whether we get a precise answer or not, you can see where the IRS is heading. To those who care about reforming the political tax rules, to reduce vagueness, ambiguity, unpredictability, excessive caution, and abuse, I would say: We need bright lines for tax-exempt political speech, and real safe harbors.

Tags: c 4 c 5 c 6 attack Citizens United electioneering issue advocacy labor unions political campaign political intervention rev. Meet the Author Gregory L. Colvin Emeritus. Our Editors Stephanie L. Petit Principal Eric K. Gorovitz Principal. Gorovitz 26 Elisabeth M. Ponsano 1 Gregory L. Broude 2 Nancy E. McGlamery 6 Robert A. Wexler 9 Rosemary E. Fei 11 Stephanie L. Publications Our attorneys stay on the cutting edge of the law and take pride in sharing their knowledge through timely and insightful updates.

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Looking for oral exchange

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