Excess benefits or private inurements occur when a benefit is received for inadequate consideration by an individual who has the ability to exercise substantial control or influence over an exempt organization
. The two categories are the disqualified person(s) and organizational manager.
The IRS's introduction of the new Form 990, Return of Organization Exempt from Income Tax, for 2008 and subsequent tax years has in some respects streamlined reporting but in other ways has significantly increased disclosure requirements for exempt organizations
. Significantly increased reporting requirements apply to exempt organization
activities outside the United States.
The audit team is part of the fiscal year 2003 IRS Exempt Organization
The IRS also requires organizations to submit Form 8718, User Fee for Exempt Organization
Determination Letter Request, along with Form 1023 or Form 1024.
ASAE argued that the IRS should not treat the provision of an Internet link from an exempt organization
to a corporate sponsor's Web site as a taxable event.
Exclusive provider arrangements generally include those that limit the sale, distribution, availability, or use of competing products, services, or facilities in connection with an exempt organization
Automatic Extensions for Information and Exempt Organization
The IRS is still in the midst of significant rulemaking procedures that are of interest to the exempt community, including the finalization of corporate sponsorship regulations and the possible creation of guidance regarding the tax treatment of exempt organization
512(b)(13), a subsidiary entity will make a deductible payment of interest, rent, royalty, or annuity to a parent exempt organization
. Under Secs.
It equated its case to the affinity-card cases in which the courts held that the payments an exempt organization
had received for the right to use its name were nontaxable royalty income.
On general issues, the IRS is looking for answers regarding the nature of an exempt organization
Thus, one can conclude that neither exempt organization
has unrelated business income because all of the income is the result of research activities.