April 2014
Intermediate to advanced
176 pages
4h 21m
English
book
Tax Planning and Compliance for Tax-Exempt Organizations, Fifth Edition 2014 Cumulative Supplement
by Jody Blazek
Content preview from Tax Planning and Compliance for Tax-Exempt Organizations, Fifth Edition 2014 Cumulative Supplement
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CHAPTER 8
Business Leagues: § 501(c)(6)
§ 8.2 Meaning of “Common Business Interest”
§ 8.4 Rendering Services for Members
*(b) Disqualifying Services to Individual Members
§ 8.2 Meaning of “Common Business Interest”
p. 170. Add after second sentence of opening paragraph:
Promoting business referrals by encouraging members to do business with other members was found by the IRS to provide personal service to individual members rather than promote the industry.1
§ 8.3 Line of Business
p. 172. Add to footnote 14:
See also Priv. Ltr. Rul. 201203018 in which the IRS denied business league status to an organization formed to connect investors, economic development organizations, public and private funds, and technology-transfer professionals to further their ability to “seed” investment in early-stage companies.
p. 173. Add to footnote 19:
See also Priv. Ltr. Rul. 201231013 in which the IRS confirmed its position that an association of pizza stores was directed at promotion of members' businesses rather than the industry as a whole.
§ 8.4 Rendering Services for Members
(b) Disqualifying Services to Individual Members
*p. 176. Add to footnote 45:
See Priv. Ltr. Rul. 201329023 in which the tax exemption of a real estate professional organization was revoked because its multiple listing service was its primary activity. It failed to satisfy all of the five attributes of a qualifying league in § 8.1.
1 Priv. Ltr. Rul. 201220034.
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