Tax Exemption: Core Concepts

1
Tax ExemptionCore ConceptsManagement
Strategies
AICPA NFP10 Session 111

• Terry Miller
• Terry_at_TerryMiller.biz
• 415-333-6320
• www.terrymiller.biz

2
Introductions

• Whos here?
• Purpose Today / Framing
• Order of Concepts
• Conceptual Legal / Public Policy Purposes
• Specific Reporting on Form 990
• Management Planning Strategies
• Questions as we go universal vs. fact specific
• Disclaimer

3
Objectives

• Objectives
• Issue spotting vs. memorize all
• nobody knows everything
• Know when to get help
• dont be penny-wise pound-foolish
• Context the concept of organized operated
• general legal compliance required
• illegal or in contravention of public policy
  ? exemption

4
Session Overview

• Context organization types / regulators / a
  word on words
• Legal concepts Tax Exemption (The Big Four
  2)
• Commerciality . . . . . . . . . . . . . . . . .
  . . . . . . . . . . . . . . . . . . . earned
  income
• Inurement . . . . . . . . . . . . . . . . . . .
  . . . . . . . . . . . . . . . . . . . . . . . .
  . insiders
• Public v. private benefit . . . . . . . . . . .
  . . . . . . . . . . . . . insiders OR
  outsiders
• Public policy advocacy . . . . . . . . . . . . .
  . . . . . . 1. lobbying, 2. electioneering
• Public charity status / public support tests . .
  . . . . . . . . for 501(c)(3) charities
• Charitable deductions substantiation
  disclosure . . . . for (c)(3) charities
• Miscellaneous compliance issues
• Reporting Form 990 the rubber hits the road
• Management strategies Planning Opportunities
• Resources
• Supplemental materials
• Related Sessions at NFP10

5
Context / Organization Types

• Types Nonprofit Corps, Trusts, LLCs, L3Cs
  STATE law
• Types of Nonprofit corporations (some states)
• Public Benefit, Mutual Benefit Religious
• Authority
• State Constitution Statutes
• Articles of Incorporation
• Bylaws
• Corporate formalities liability protection
  (piercing the veil)
• SOS Registration
• IRS Income Tax Exemption Charitable Tax
  Deductions
• AG Charitable Trust Charitable Solicitation
  Registration
• Charitable Solicitation Registration
• cy pres
• ?? Sales Property Tax Exemption, Charitable
  Gaming

6
Taxation? But were a nonprofit ?!

• Nonprofit state corporation concept
• Tax law levels of benefit by type of Exempt
  Organization, known by Internal Revenue Code
  Section
• 501(c)(1) Created by Congress (c)(2) Title
  Holding
• 501(c)(3) Charities
• Public Charities
• Private Foundations
• 501(c)(4) Social Welfare / Civic Leagues
• 501(c)(5) Labor / Horticultural
• 501(c)(6) Biz League / Prof Trade Assoc /
  Chamber Commerce
• 501(c)(7) Social Clubs
• .up to 501(c)(27) and beyond501(d,e,f,k,n), 527

7
More complicated than taxable for-profits

• The notion of organized and operated
  exclusively
• Form 990 is mind-numbing
• Measure whether sufficient exempt function
  activity is occurring to justify favorable tax
  treatment
• Commensurate test
• Tax Exempt (most net income not taxable)
• Tax Deductible (mostly 501(c)(3) organizations)
• Form 990 as a Public Communication tool
• Heightened public focus stoked by scandals
• 2008 Form 990 overhaul first in 30 years

8
A word on words

• nonprofit, not-for-profit
• charity
• charitable trust
• EO exempt organization income tax-exempt
• tax deductible as a charitable gift tax
  deduction
• c3 c4
• PF PC
• new 990
• income support revenue
• UBI UBTI UBIT
• exclusive substantial primary
• facts circumstances

9
Legal Concepts

• Legal Concepts
• the Big Four
• (plus assorted details
• the fine print ? )

10
Internal Revenue Code501(c) (3) (Complete!
)

• (3) Corporations, and any community chest, fund,
  or foundation, organized and operated exclusively
  for religious, charitable, scientific, testing
  for public safety, literary, or educational
  purposes, or to foster national or international
  amateur sports competition (but only if no part
  of its activities involve the provision of
  athletic facilities or equipment), or for the
  prevention of cruelty to children or animals, no
  part of the net earnings of which inures to the
  benefit of any private shareholder or individual,
  no substantial part of the activities of which is
  carrying on propaganda, or otherwise attempting,
  to influence legislation (except as otherwise
  provided in subsection (h)), and which does not
  participate in, or intervene in (including the
  publishing or distributing of statements), any
  political campaign on behalf of (or in opposition
  to) any candidate for public office.

(color, bold underlines added)
11
Internal Revenue Code501(c) (4),(5) (6)
(Complete)

• (4) (A) Civic leagues or organizations not
  organized for profit but operated exclusively for
  the promotion of social welfare, or local
  associations of employees, the membership of
  which is limited to the employees of a designated
  person or persons in a particular municipality,
  and the net earnings of which are devoted
  exclusively to charitable, educational, or
  recreational purposes.
• (B) Subparagraph (A) shall not apply to an
  entity unless no part of the net earnings of such
  entity inures to the benefit of any private
  shareholder or individual.
• (5) Labor, agricultural, or horticultural
  organizations.
• (6) Business leagues, chambers of commerce,
  real-estate boards, boards of trade, or
  professional football leagues (whether or not
  administering a pension fund for football
  players), not organized for profit and no part of
  the net earnings of which inures to the benefit
  of any private shareholder or individual.

(color, bold underlines added)
12
Legal Concepts The Big Four

• Commerciality
• How much can we operate like a business and still
  be tax exempt?
• Can we charge for services?
• Private Inurement - Insiders
• How much can we pay the boss?
• Can we rent from the Chairperson?
• Public vs. Private Benefit
• Who really benefits from our work, on balance?
• Politics Lobbying
• Can we support candidates for office?
• Can we join a coalition to oppose legislation?

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Commerciality -1

• History
• destination test, until
• NYU / Mueller Macaroni, circa 1950
• Pizza parlor example operated for charitable
  (not commercial) purpose
• Exempt function income / program service
  revenue
• income as a by-product of program activity
• The concept of Unrelated Business Income (Tax)
• trade or business
• regularly carried on
• unrelated to the exempt purpose

14
Commerciality -2

• Common problem / error technical assistance
• substantially below cost
• Useful exclusions from UBI follow from definition
• passive not carried on at all
• interest, rents royalties (watch out for
  debt-financed property)
• gains losses
• not regularly carried on
• substantially by volunteers not trade or
  business
• sale of donated merchandise not trade or
  business
• convenience of patrons related
• All revenues are one of these three
• Related Exempt Function Income (a/k/a program
  svc revenue)
• UBTI
• UBI but for exclusion

15
Commerciality -3

• Qualified Sponsorship Payments (v. advertising)
• no price item, inducement to buy, comparative
  messaging
• watch out for web links!
• RESOURCE Session 19 (qualified sponsorships)
• Dual types For-Profit Nonprofit/EO (e.g.
  hospitals)
• usually means there will be specific guidance
• frustrating issue evolutionary enterprises
  (e.g. schools) poaching
• RESOURCE Session 55 (hospitals community
  benefit)
• Commercial sub-activities
• when UBI activity becomes jeopardizing
  substantial (?)
• for-profit subsidiary

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Private Inurement -1

• about INSIDERS (power to exercise major
  influence)
• History William Aramony
• (resigned 1992, convicted 1995, released 2001)
• Need for Intermediate Sanctions IRC 4958
• Continued concern driven by juicy scandals
  Smithsonian, American University, Irvine
  Foundation, etc etc etc
• Excess compensation most common issue
• Excess Benefit Transactions includes loans
  other (buy/sell/rent)
• T. Pattara says Grassley on a tear about this
  (recent news about Grassley Boys Girls Clubs)
  Congress as a wild card

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Private Inurement -2

• Conflicts of Interest / Conflict of Interest
  Policies
• Definition?
• IRS concerned about self-dealing
• Confidential information? Settling scores?
• Who covered?
• IRS directors officers (they define officer
  to include CEO CFO)
• All employees? Volunteers?
• What relationships to report?
• IRS close family business
• Domestic partners? Best friends?
• How declared?
• IRS at least annually report all
  relationships that could give rise
• Duty of loyalty develop sensitivities to
  disclosure openness
• How monitored enforced?
• Disclosure recusal is usually enough

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Private Inurement -3

• Section 4958 Overview (c)(3) pub charities
  (c)(4) orgs
• Penalties doubled by Pension Protection Act
• Severe on individuals
• notion of intermediate sanctions scrambled up
  by Caracci case
• 4958 rebuttable presumption basics re
  disqualified persons
• Written comparables, saved with minutes
• Disinterested majority of board, with interested
  party/parties out of room
• Good faith determination best interest of the
  organization
• Prior to transaction
• Some in Congress want safe harbor steps required
• IRS considers it best practice pressure to
  report
• IRS concerned about quality of comparables
• Risks notion of Automatic Excess Benefit
  Transactions / Listed Property
• RESOURCES Session 48 (intermediate sanctions)
• Session 53 (comparability audits)

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Public v. Private Benefit -1

• 501(c)(3)s 501(c)(4)s
• Subtle / requires step back ask who really
  benefits?
• NOT about insiders, necessarily
• avoid more than incidental private benefit
• the presence of private benefit, if substantial
  in nature, will destroy tax-exempt status
  regardless of an organizations other charitable
  purposes or activities Marcus Owens on Better
  Business Bureau case (Resources)
• Charitable class how big? Public?
• Private Benefit IRS new all-purpose hammer?
• commensurate test
• efficiency effectiveness
• dovetails with public skepticism

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Public v. Private Benefit -2

• Famous cases
• American Campaign Academy
• Consumer Credit Counseling
• current Seller-financed Down Payment Assistance
• Governance as indicator of risk audit flag
• v. denial of exemption application
• unpredictable
• good governance policies controls Owens paper
  (Pg 111-64), e.g.
• broad Board
• clear records on achievements
• conflict of interest whistleblower policies
• commitment to proper arms length
• outside auditor if big enough, internal auditor
• greater disclosure than required
• accountable plan for reimbursements
• compensation process use rebuttable presumption

21
Public Policy AdvocacyLobbying v. Politics

• Key distinction Lobbying v. Candidate
  Electioneering
• big danger in jumbling them !!
• C3 Public Charity Lobbying legislation
• including work on referenda even though elections
  involved
• C456 Lobbying legislation
• plus certain executive branch decision making
• Electioneering candidates for elected office
• some targeted lobbying IS electioneering

22
Public Policy Advocacy Lobbying -1

• 501(c)(3) Public Charities
• History 1930, 1934, 1955, 1970, 1990
• Expenditure Test v. Substantial Part Test
• Expenditure Test more objective (IRC 501(h),
  Regs 4911)
• Direct v. Grassroots lobbying
• Specific legislative proposal
• Substantial Part Test facts circumstances
• 501(c)(3) Private Foundations
• No explicit lobbying (earmarked / restricted)
• Some wiggle room (general support, or project
  support less than the non-lobbying portion of the
  project)
• mostly they just dont want to hear about it ?

23
Public Policy Advocacy Lobbying -2

• 501(c)(non-3) Exempt Organizations
• Unlimited if related to exempt purpose
• 501(c)(4)s (NRA, Sierra Club, etc) lobby a LOT
• 501(c)(5) (Labor unions, Farm Bureau) lobby a LOT
• 501(c)(6) (Trade associations, chambers of
  commerce, professional associations) lobby a LOT
• 501(c)(7) social recreational not so much
• Different definitions legislation (other than
  local), plus certain executive branch policies
• Business dues non-deductible as biz expense if
  used for lobbying, must apply dues income first
  to Lobbying
• Notify members of non-deductible portion, or
• Pay 35 proxy tax

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Public Policy Advocacy Lobbying -3

• Remember this has been about TAX law
• Fed / State / (Local?) ethics registration
  rules such as Congressional Lobbying Disclosure
  Act (LDA)
• Trigger points ( level)
• Different definitions
• Wining dining gifts travel, money in
  politics, including by individuals from
  organization (!)
• LDA allows public charities that have elected the
  expenditure test to use some of the tax
  definitions
• Ballot measures may involve State election
  commissions and PAC regulation / registration /
  reporting
• RESOURCE Session 43 (elect lobbying
  reporting beyond tax)

25
Public Policy Advocacy Candidate
Electioneering -1

• IRC Section 527 527 Activities political
  electioneering
• True meaning influence the election of
  candidates
• 527 As used in the press issue advocacy
  targeted at influencing election of candidates
  which escapes election commission jurisdiction by
  not being explicit
• will Citizens United kill off such issue 527s
  of this sort?
• 501(c)(3) Charities (both PC PF)
• CANDIDATE ELECTIONEERING PROHIBITED
• Revocation and/or penalties on charity AND on
  individuals (Board)
• Non-partisan voter registration, voter education
  get out the vote are all OK if done just right
• (think League of Women Voters)

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Public Policy Advocacy Candidate
Electioneering -2

• 501(c)(4,5,6 ) organizations
• Must be not primary purpose, conducted legally,
  and consistent with overall exempt purpose
• Primary 51/49? No clear standard
• EACH year, no rolling periods
• Legal jurisdiction of FEC or State/Local
  equivalents
• Usually means hiring election law counel
• Notion of Separate Segregated Fund
• 527 Organizations
• Not just soft PACs / issue 527s includes
  parties, candidate cttees
• Risk if not political enough
• (more than insubstantial non-exempt purposes)

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Recap The Big Four

• Commerciality
• Exempt Function Income
• Unrelated Business Income
• UBI but for Exclusion(s)
• Inurement insiders
• Public v. Private Benefit insiders or outsiders
• Public Policy Advocacy
• Lobbying v. Candidate Electioneering
• Next
• Private Foundation v. Public Charity the public
  support tests
• Charitable Deduction Rules
• Misc Compliance Issues

28
501(c)(3) Public Charity or Private Foundation?

• 501(c)(3) charities are private foundations (PF)
  by default, unless can qualify as a public
  charity (PC)
• status tests (e.g. school) or public support
  tests
• Grandmas Foundation vs. Publicly-Supported
  Charity
• PC is better much less regulated than PF
• better donor deductibility ( of AGI, FMV v.
  Basis)
• more transactions with insiders allowed safe
  harbor avail (for now)
• no tax on investment income, fewer excise tax
  penalties
• may MAKE grants to any entity (including foreign)
  for specific charitable purposes (if entity not a
  c3)
• only practical way to get many PF grants is to be
  a PC
• may lobby

29
PC or PF?Types of Public Charity

• Qualify as Public Charity under IRC 509(a)(1)-(4)
• 509(a)(1) says 170(b)(1)(A)(i) - (vi)
• 170(b)(1)(A)(i) Church status
• 170(b)(1)(A)(ii) School status
• 170(b)(1)(A)(iii) Hospital / medical research
  org status
• 170(b)(1)(A)(iv) Support org to public college or
  univ status
• 170(b)(1)(A)(v) Governmental unit status
• 170(b)(1)(A)(vi) Publicly supported charity
  gifts test
• 509(a)(2) Publicly supported charity fees test
• 509(a)(3) Supporting Org (four sub-types ?) mix
• RESOURCE Session 47 (supporting organizations)
• 509(a)(4) Product Safety Testing Org status

30
PC or PF? Public Support Test(s)

• Two Public Support Tests
• Both are complex dynamic formula (mix of donors
  revenues by size)
• 5 year measurement period
• Advance period for startup dont prove until
  Year 6 (2-3-4-5-6)
• 509(a)(1) 170(b)(1)(A)(vi) broad gift support
• more forgiving and flexible than (a)(2)
• some changes with New 990
• 509(a)(2) broad base of earned revenue from
  program services, plus very small gifts
• extraordinarily complex math 1 yr, 5 yr data
  from inception
• unforgiving, inflexible test
• switching between is OK

31
Donor Deductibility -1

• Donor Substantiation (Receipting)
• Publication 1771 Deeper Pub 526
• Cash ( Un-reimbursed Volunteer Participation)
  Gifts gt 250
• donor must have receipt with required language if
  audited
• Cash v. Non-Cash gifts
• valuation internal estimate (books) v. donor
  receipt (no value estimate!)
• for charitable use vs. for resale key issue
• Quid pro Quo gifts gt 75
• FMV, not cost, stated in Solicitation or Receipt
• TIP fundraising events need TWO income lines
  each
• exception low cost logo items (coffee mug) for
  certain gifts
• Common Errors
• Donated services ( whole concept of confusion
  about a write-off)
• Earmarked for individual beneficiaries
• Non-cash valuations estimated on receipt (donor
  pressure!)

earned donated
32
Donor Deductibility -2

• Intangible Membership Religious Benefits
• best to read Pub 1771
• rules are pretty common-sense
• Penalties
• Failure to disclose non-deductibility (attn C4s!)
• Failure to provide quid-pro-quo information
• Vehicles, Boats Planes Pub 526
• general direction of law
• Other high-value non-cash items
• 8282 / 8283
• RESOURCE Session 24 (charitable contribution
  compliance)

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Other Compliance Issues

• 990 Disclosure (Guidestar does not count)
• 1023/1024 Disclosure
• Complete Accurate Return statute of
  limitations, penalties if severe
• Late Filing Penalties
• 3 years Non-Filing Revocation
• Donor Advised Funds certain fiscal
  sponsorships
• Abuses 1) parking place, 2) self-serving
  grants, 3) self-serving investments
• RESOURCE Session 59 (working with community
  fdns)
• Foreign Activity PATRIOT Act / know your
  customer
• RESOURCE Session 36 (foreign operations)

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Reporting Form 990

• Reporting
• Form 990
• (the rubber hits the road)

35
Key Parts of the New 990Core Form
PART

• I Summary (dashboard for the public)
• III Program Service Accomplishments
  (commensurate test)
• IV Checklist of Required Schedules (trigger
  questions)
• V Other Filings Tax Compliance (various
  compliance)
• VI Governance, Mgt Disclosure (private
  benefit / inurement)
• VII Compensation (inurement)
• VIII Revenue (commerciality UBI analysis)
• IX Functional Expenses (commensurate test)
• X Balance Sheet (inurement)

36
New 990The 16 Schedules -1

• (Which schedules to file? Based on trigger
  question thresholds)
• A Public Support Tests / Pub Char Status (public
  charity status)
• B Contributors (no change from old
  990) (deductibility)
• C Campaign Lobbying Activity (public policy
  advocacy)
• D Supplemental Financial Statement
  Detail (various)
• E Private Schools Education (no substantive
  change) (special)
• F Foreign Activities Grants (special PATRIOT
  Act / terrorism)
• G Gaming ( Fundraising) (commerciality private
  benefit)
• H Hospitals (commensurate test public benefit)

SCHEDULE
37
New 990The 16 Schedules -2

• I Grants (Domestic - Inside U.S.) (public
  benefit)
• J (Justify) Compensation (inurement)
• K Bonds (public benefit compliance)
• L Loans (inurement)
• M Non-Cash Contributions (deductibility excess
  benefit)
• N Termination / Disposition of Assets (inurement
  / public benefit)
• O Open for Narrative Responses (various)
• R Related Organizations (various / public
  benefit)

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990 Core Form Pg 1

• see Full-Size Form
• in
• Supplemental Materials !
• (Page 23)
• Core Form Page 1
• Parts I and II
• Dashboard / Overview

39
990 Core Form Pg 2

• Core Form Page 2
• Part III
• Program Accomplishments
• Commensurate Test
• Key Communication Tool

40
990 Core Form Pg 3

• Core Form Page 3
• Part IV
• Trigger Questions
• threshold(s) where IRS has concern

41
990 Core Form Pg 4

• Core Form Page 4
• Part IV continued

42
990 Core Form Pg 5

• Core Form Page 5
• Part V
• Other Filings Compliance

43
990 Core Form Pg 6

• Core Form Page 6
• Part VI
• Governance, Management Disclosure
• IRS Theory Public v. Private Benefit risk
  assessment audit flags
• BIG emphasis

44
990 Core Form Pg 7

• Core Form Page 7
• Part VII
• Compensation of
• Officers
• Directors (Trustees)
• Key employees
• Highest comped ees
• Former ODKEs
• Inurement
• IRS Focus audit flags more BIG emphasis

45
990 Core Form Pg 8

• Core Form Page 8
• Part VII continued

Trigger Questions
46
990 Core Form Pg 9

• Core Form Page 9
• Part VIII
• Income (Revenue)
• Support v. revenue
• Classify revenues
• Related
• UBTI
• UBI but for exclusion

47
990 Core Form Pg 10

• Core Form Page 10
• Part IX
• Functional expenses
• Program
• Mgt Gen (Admin)
• Fundraising

48
990 Core Form Pg 11

• Core Form Page 11
• Part X
• Balance Sheet
• Inurement

49
990 Core Form Pg 12

• Core Form Page 12
• Part XI
• Accounting methods, auditors, etc

50
Schedule HighlightsSchedule J Pg 1

• Schedule J Page 1
• Inurement
• compensation setting basis practices
• compensation-like reimbursements

51
Schedule HighlightsSchedule L

• Schedule L
• Inurement Loans other transactions with
  insiders

52
Schedule HighlightsSchedule M Pg 1

• Schedule M, Page 1
• Deductibility non-cash gifts
• Private benefit / excess benefit certain
  hard-to-value noncash gifts

Governance Type Questions
53
Planning Strategies

• Management
• Planning Strategies

54
Planning Strategies -1

• General
• Fads fashions in tax law enforcement
• Unfortunate but true
• Australia the tall poppy syndrome
• Read trade publications
• Congress official individual
• Sen. Grassley, but earlier was J.J. Pickle
• Subscribe to IRS free EO Update newsletter
• Read Chronicle of Philanthropy
• Retain counsel

55
Planning Strategies -2

• Commerciality
• Broaden exempt purposes amend articles, review
  1023
• Master exclusions
• Logo wear vs. message wear
• Sponsorship deals
• if UBTI calculate expenses with consistent
  methodology
• if UBTI approaching substantial activity
  for-profit subsidiary
• Inurement
• Benchmarking not everyone is above average /
  75th ile ?
• Audit committees value squeaky wheels avoid
  groupthink
• Compensation committee do regular review
  document
• Learn to spot compensatory reasoning and handle
  it correctly
• watch out for listed property
• Managing even the appearance of Conflicts of
  Interest

56
Planning Strategies -3

• Public v. Private Benefit
• Commensurate test think critically
• Mission (re)-evaluation regularly
• New blood
• Take governance seriously
• Public Policy Advocacy
• Master the lobbying rules
• Find one person or committee to really master it
• Train train train
• C3s Watch out for Election Years
• Consider tandem c3/c4 or triad c3/c4/527

57
Planning Strategies -4

• Public Support
• the notion of tipping
• run a test at Year 3
• dont panic about 10 facts circumstances
• if tipping, consider alternates
• 509(a)(3)
• 501(c)(4)
• private foundation
• private operating foundation
• sponsored project
• merger into / with another public charity

58
Resources Supplemental Materials

• Supplemental Materials
• Form 990 markups Core Form, Schedules J (Pg 1),
  L, M (Pg 1) 33
• Types of Tax Exempt Organizations (from
  IRS.gov) 48
• Nonprofit Governance, and Effectiveness and
  Efficiency of Operations, speech by former IRS
  EO Commissioner Steven T. Miller, April 2008 50
• Current Climate for Charities, speech by
  Miller, October 2007 58
• More Scrutiny of Charities Expected, Regulators
  Told, article about IRS EO Director Lois Lerner
  speech to NASCO 63
• UBTI exclusion codes good short reference (from
  2007 990 instructions) 66
• Private vs. Public Benefit, Marcus Owens, 2007,
  AICPA NFP conference 67
• IRS Pub 1771 Charitable Contributions
  Substantiation Disclosure 76
• Bibliography Public Policy Advocacy 84
• Additional Resources 93

59
Resources Directly Related Sessions at NFP10

• 19 Qualified Sponsorship Payments (commerciality)
  
• 22 2009-2010 Tax Year Update (repeats in
  49) (general)
• 24 Charitable Contribution Compliance (donor
  deductions)
• 36 Foreign Operations / Schedule
  F (anti-terrorism)
• 42 New 990 Lessons Ambiguities (general)
• 43 Election Lobbying Reporting Beyond
  Tax (policy advocacy)
• 47 Supporting Organizations (public charity
  status)
• 48 Compliance w/ Intermediate Sanctions Rules
  4958 (inurement)
• 49 (repeat) 2009-2010 Tax Year Update (general)
• 53 Managing Comparability Compensation
  Audits (inurement)
• 55 Hospitals Community Benefit (special)
• 58 Ask the Experts Panel Tax (varies)
• 59 Working with Community Fdns Planning
  Opptys (public support)

60
Resources Other EO Tax Sessions at NFP10

• 202 Form 990-T Whats New? (commerciality-UBIT
  / general)
• 205 Reporting 403(b) Plans on Form
  5500 (inurement)
• 6 View from the IRS (general)
• 13 Issues With Related Affiliated
  Orgs (varies)
• 18 Tax Exempt Bond Compliance (varies)
• 25 Tax Ethics / Practitioners (varies)
• 30 Private Foundations Current Developments
  (PF / advanced)
• 35 Form 990 Part IX / Functional
  Accounting (commensurate test)
• 54 Alternative Investments (charitable trust)
• 60 Advanced Non-Qualified Deferred
  Comp (inurement)

61
End

• Questions?