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Recent Commentary
Diving into Endowments: UPMIFA and More
The law of endowments has changed dramatically, just in time for our new "down" market. This article focuses on the law of endowments, the new accounting rules, and the challenges facing charities in determining their endowment spending rates. This also reviews a few "new" ideas for donors reluctant to give to the traditional endowment.
Group Exemption Reporting Requires New Form
On July 14, 2026, IRS announced that central organizations are required to use Form 15644 (Form) to make their annual Supplemental Group Ruling Information submissions.
Underperforming NIMCRUT
Donors are able to terminate a NIMCRUT while providing valuable liquidity, retaining up-front tax benefits, maximizing dollars to donors, and garnering long-term capital gain tax treatment on what would have been ordinary income.

Rev. Proc. 2026-30 Streamlines Applications for Certain Letter Rulings-
In Rev. Proc. 2026-30, IRS updated the application procedures for requesting letter rulings and nonbank trustee approval letters under the jurisdiction of the Employee Plans Rulings and Agreements Office of the Tax Exempt and Government Entities Division (Ruling Requests). All such requests on or after September 4th must be submitted electronically.