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On September 10, 2019, the Internal Revenue Service issued proposed updates to the information reporting regulations applicable to tax-exempt organizations. The proposed regulations  generally incorporate existing statutory amendments and IRS guidance provided since the current regulations were adopted.

Among the proposals is a regulation that would put into effect the changes previously announced in Revenue

On July 30, 2019, the court in Bullock v. IRS, No. CV-18-103-GF-BMM (D. Mont. July 30, 2019) invalidated IRS Revenue Procedure 2018-38 governing tax-exempt organizations’ disclosure of donor information on the grounds that it was promulgated without the required notice-and-comment period.

Background

As described in our previous blog post, prior to Revenue Procedure

The Internal Revenue Service (“IRS”) defines virtual currency as “a digital representation of value that functions as a medium of exchange, a unit of account, and/or a store of value.” Virtual currency is not backed by a government-issued legal tender. Convertible virtual currency such as Bitcoin—by far the most popular—may be used to pay for

On May 6, 2019, the New York and New Jersey Attorneys General filed a lawsuit against the U.S. Department of the Treasury (the “Treasury Department”) and its bureau the Internal Revenue Service (the “IRS”) for failing to respond records requests made pursuant to the Freedom of Information Act (“FOIA”). The requests sought records and information

On July 19, 2018, the New York Attorney General announced a settlement with Tennessee-based charity Operation Troop Aid Inc. (“OTA”) for failure to properly oversee donations received as part of a commercial co-venture.

OTA operated for the stated purpose of sending care packages to military service members, primarily during deployment. From at least 2012 to

Internal Revenue Service Notice 2018-67 (the “Notice”) sets forth interim guidance relating to Internal Revenue Code § 512(a)(6) Special rule for organization with more than one unrelated trade or business.

Enacted on December 22, 2017 as part of Public Law 115-97 (the “Tax Cuts and Jobs Act”), Code § 512(a)(6) provides that

in the