The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement. Bruce R. Hopkins

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The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement - Bruce R. Hopkins


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does not apply in this context. Nonetheless, organizations have the option of determining public support using their unrelated business taxable income calculated under the bucketing rule or in the aggregate.

       p. 304. Insert as second complete paragraph:

       p. 302, note 167. Delete last sentence and insert:

      Illustrations of organizations satisfying these requirements are the subject of Priv. Ltr. Ruls. 201936002, 201936003, and 201307008.

       p. 305, note 193, first line. Insert following second period:

      Supported organizations are the subject of IRC § 509(f)(3).

       p. 309, note 234, first paragraph. Insert as last sentence:

      An illustration of a situation where a tax‐exempt business league should have placed its substantial charitable and educational activities in a separate organization, such as a supporting organization, is provided in Priv. Ltr. Rul. 202017035.

       p. 309, note 234, fourth paragraph, last line. Delete citation and insert:

      F. Supp. 3d 949 (W.D. Wis. 2017).

       p. 309, note 234, fourth paragraph. Insert as last sentences:

      In a subsequent decision, this court held that the trustees of the supporting organization repeatedly breached fiduciary duties to the supported organization, to the end that the fees and costs owed to the supported organization must be paid by the trustees of the supporting organization personally, a trustee must be removed, and an institutional trustee selected (Cohen v. Minneapolis Jewish Fed'n, 346 F. Supp. 3d 1274 (W.D. Wis. 2018)). These decisions were affirmed, with the appellate court writing that “[w]e do not think it necessary to add to the district court's explanation of these decisions, all of which are either compelled by law (including the law of contracts and the Internal Revenue Code) or within the scope of remedial discretion allowed to a court by Wisconsin's law of trusts” (Cohen v. Minneapolis Jewish Fed'n, 776 Fed. Appx. 912, 913 (7th Cir. 2019)).

      (f) Other Provisions

       p. 321, last paragraph. Delete first sentence, including footnote, and insert:

      1 155.1 Reg. § 1.170A‐9(f)(7)(v).

      2 155.2 See § 25.5.

      3 185.1 Reg. § 1.509(a)‐3(a)(3)(i), (4).

      4 185.2 See § 25.5.

      5 362 IRC § 4940. This law change was occasioned by enactment of the Taxpayer Certainty and Disaster Tax Relief Act of 2019 § 206; this act is Division Q of the Further Consolidated Appropriations act, 2020 (Pub. L. No. 116‐94).

        § 13.1 Concept of Social Welfare (b) Benefits to Members

        § 13.3 Conduct of Business

       p. 326, first complete paragraph. Insert as last sentence:

      (b) Benefits to Members

       p. 330, carryover paragraph. Insert as last sentence:

       p. 336. Insert following carryover paragraph, before heading:

      1 11.1 E.g., Priv. Ltr. Rul. 202015036.

      2 54.1 Priv. Ltr. Rul. 201907013.

      3 113.1 Priv. Ltr. Rul. 201941028.

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