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Four PLRs Approve Settlement of Dispute Involving GST-Exempt Trusts

Monday, May 4, 2015

In four identical rulings, PLRs 201518002 through 201518005, the Service ruled the settlement of litigation involving four trusts would not cause any of the trusts to lose its status as exempt from the generation-skipping transfer tax.

PLR 201518019 - Scholarship Exception Ruling

Monday, May 4, 2015

In PLR 201518019, the Service determined a private foundation's grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

TIGTA Reports on IRS Efforts to Improve Processing of "Political" (c)(4) Applications

Monday, May 4, 2015


Nearly two years after the scandal broke over IRS targeting of conservative organizations applying for (c)(4) tax-exempt status, the Treasury Inspector General for Tax Administration issued a report (the "Report") finding the agency has taken "significant actions" to eliminate the use of improper criteria to select political cases for review.

PLR 201518007 - Late Election of Two-Month Lookback for CLATs

Monday, May 4, 2015

In PLR 201518007, the Service exercised its discretion to allow a transferor belatedly to elect to value the remainder gift on each of two nongrantor charitable remainder annuity trusts using the Section 7520 rate from two months prior to the date of the gift.

9th Circuit Affirms Denial of Preliminary Injunction in Donor Disclosure Case

Monday, May 4, 2015

Finding no "actual burden" on the First Amendment freedom of association of its members, the 9th Circuit federal appeals court in Center for Competitive Politics v. Harris affirmed a trial court order. The lower court denied a preliminary injunction to prevent the California state attorney general from requiring a 501(c)(3) organization to submit unredacted copies of Schedule B of its Form 990 filings and disclosing the names of its "significant donors."

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