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Two Scholarship Exception Rulings

Monday, July 28, 2014

In two unrelated rulings, PLRs 201430015 and 201430016, the Service determined a private foundation's grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

Six Rulings on Inherited IRAs and Spousal Rollovers

Monday, July 28, 2014

Among this week's release of private letter rulings were six rulings dealing with issues arising from imperfect beneficiary designations on decedents' IRAs.

TAM 201430019 - Nonmember Receipts by Social Club Within Limits

Monday, July 28, 2014

In TAM 201430019, TE/GE Technical advised an area appeals office that the 501(c)(7) status of a social organization for owners of a particular make of automobile should not be revoked on the basis of its receipts from nonmembers.

PLR 201430018 - Regional Transmission Entity May Serve as Transaction Counterparty

Monday, July 28, 2014

In PLR 201430018, the Service ruled a regional transmission organization ("RTO") regulating the transmission and wholesale of electrical energy could act as the central counterparty for transactions between producers and wholesalers of electricity, without endangering its Section 501(c)(6) status. Further, the Service determined revenues derived from these transactions would not constitute unrelated business taxable income.

PLR 201430017 - Foreign Subsidiary Operates as UBTI "Blocker"

Monday, July 28, 2014

In PLR 201430017, the Service ruled favorably on a nonoperating private foundation's plan to make investments through a foreign subsidiary that would normally generate unrelated business taxable income.

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