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Recent Commentary
PLR 202631012 - IRS Rejects Business League Exemption Under Six-Factor Test
In PLR 202631012 (PLR), IRS concluded that a membership-based angel investor group (Organization) did not qualify for tax-exempt status under Section 501(c)(6) as it failed to satisfy five of the six requirements applicable to business league classification under Reg. Sec. 1.501(c)(6)-1.
FinCEN Releases Final Ruling on Beneficial Ownership Reporting
On August 14, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) published its final rule (Final Rule) in the Federal Register, effectively solidifying exemptions for U.S. persons and domestic entities from beneficial ownership information (BOI) reporting.
Rate for Charitable Calculations Grows to 5.4%
In Rev. Rul. 2026-17, the Service announced the Section 7520 rate for September will grow to 5.4%. The average rate for 2025 was 4.95%, while the average rate for 2026 is 4.93%.

Charitable Gift Annuity Reinsurance: What It Is, What It Isn't and When It Works and When It Doesn't-
Gift annuity reinsurance has long been a misunderstood topic. Life insurance companies suggest reinsuring everything. Investment managers suggest reinsuring nothing. Like most things in life, there is a prudent middle-ground. Charities have never been so concerned about gift annuity pools and are exploring every possible option for risk management. This article helps people better understand what reinsurance can and can't do to mitigate risk. Case studies are used to answer most of the frequently asked reinsurance questions.