Tax Exempt and Government Entities Issue Snapshots


Issue Snapshots are employee job aids that provide analysis and resources for a given technical tax issue. They are developed through internal collaboration and may evolve as the compliance environment changes and new insights and experiences are contributed. Please visit this site periodically for new and updated Issue Snapshots.

Charities and Non-Profits

Date Title
02/11/2016 IRC Section 4942 Taxes on Failure to Distribute Income Carryover of Excess Distributions or Undistributed Income
03/10/2016 Lessening the Burdens of Government as a Basis for Tax Exemption under IRC Section 501(c)(3)
05/22/2016 Electronic Health Records (EHRs) or Regional Health Information Organization (RHIOs)
08/10/2016 Abatement of Chapter 42 First Tier Taxes due to Reasonable Cause
08/12/2016 IRC Section 4946 - Definition of Disqualified Person
09/29/2016 Advertising or Qualified Sponsorship Payments?
11/09/2016 Request for Private Operating Foundation Classification under IRC 4942(j)(3)
12/19/2016 Administrative expenses treated as qualifying distributions for the purposes of IRC Section 4942 - Taxes on Failure to Distribute Income
04/19/2017 IRC Section 4943 - Tax on excess business holdings
04/28/2017 Deductibility of Contributions From Gaming Proceeds as Section 162 Business Expenses for Calculation of Unrelated Business Taxable Income by an Exempt Organization
05/12/2017 Volunteer Labor Exclusion from Unrelated Trade or Business
05/24/2017 Identification and Treatment of Income from Mailing Lists
06/16/2017 Exclusive Provider Arrangement within Qualified Sponsorship Agreements
08/28/2017 IRC Section 4945(h) – Expenditure Responsibility
08/31/2017 The Enduring Relevance of Rev. Proc. 71-17 on IRC Section 501(c)(7) Organizations
09/14/2017 IRC Section 4944(c) – Taxes on Investments Which Jeopardize Charitable Purpose – Exception for Program-Related Investments
10/18/2017 Exclusion of Bingo from Unrelated Business Activity
10/18/2017 Rents from Personal Property, “Mixed Leases,” and the Rental Exclusion from UBTI
10/18/2017 Exclusion of Rent from Real Property from Unrelated Business Taxable Income
11/09/2017 Entities Engaged in the Corporate Practice of Medicine
11/15/2017 Unrelated Business Income from Debt-Financed Property under IRC Section 514
03/28/2018 Agricultural Organizations Described in IRC 501(c)(5)
03/28/2017 Fraternal Organizations: What Constitutes a Lodge System?
04/03/2018 Financial Assistance Policies (FAPs)
04/03/2018 Hospital Definition Under IRC Sections 509(a)(1) and 170(b)(1)(A)(iii) versus IRC Section 501(r)


Exempt Organization Gaming and Unrelated Business Taxable Income

05/21/2018 Section 4959 Excise Tax for Failure to Meet the Requirements of Section 501(r)(3) and Noncompliant Facility Income Tax for Failure to Meet the Requirements of Section 501(r)
05/21/2018 IRC Section 4941(d)(2)(E) - Taxes on Self-Dealing, Special Rules
06/02/2018 Understanding How Income Affects Qualification for Exemption as a IRC Section 501(c)(2) Corporation
08/06/2018 Section 507(b) Termination of Private Foundation Status, Special Rules
03/21/2019 Private Foundations – Issues Encountered Once a Self-Dealing Transaction Has Occurred
08/09/2019 Benefits Considerations for Fraternal Organizations Described in IRC Section 501(c)(8)
08/12/2019 2018 Fiscal Year: Blended Tax Rates for Corporations
10/22/2019 Private Foundations - Self-Dealing IRC 4941(d)(1)(A)
10/22/2019 Private Foundations - Self-Dealing IRC 4941(d)(1)(B)

Private Foundations – Self-Dealing IRC 4941(d)(1)(C)

02/13/2020 IRC Section 501(c)(4) Homeowners’ Associations

Retirement Plans

Date Title
04/15/2016 Written Plan Document Requirement for 403(b) Plans
04/15/2016 Expansion of Rollover Options Includes Savings Incentive Match Plan for Employees (SIMPLE) IRA Plans
04/15/2016 Church Plans, Automatic Contribution Arrangements, and the Consolidated Appropriations Act, 2016
08/01/2016 Notice Requirement for a Safe Harbor 401(k) or 401(m) Plan
08/01/2016 Mid Year Changes to Safe Harbor Plans or Safe Harbor Notices
09/22/2016 Change to Plan Vesting Schedules
09/26/2016 Consequences to a Participant Who Makes Excess Deferrals to a 401(k) Plan
12/19/2016 403(b) Universal Availability Requirement
02/22/2017 401(k) Plan Catch-up Contribution Eligibility
03/10/2017 401(k) Automatic Contribution Arrangements - General Annual Participant Notice
04/06/2017 Investments in Collectibles in Individually-Directed Qualified Plan Accounts
04/07/2017 Definitely Determinable Benefits
04/21/2017 Identifying Highly Compensated Employees in an Initial or Short Plan Year
04/31/2017 Treatment of Otherwise Excludable Employees for Coverage and ADP Testing
05/18/2017 Partial Termination of Plan
05/31/2017 Compensation Definition in Safe Harbor 401(k) Plans
06/20/2017 Improper Forfeiture by Defined Benefit Plans
08/22/2017 403(b) Plan – Plan Aggregation in Determining Compliance with IRC Section 415(c)
08/23/2017 IRC Section 457(b) Eligible Deferred Compensation Plan – Written Plan Requirement
05/18/2018 Plan Forfeitures Used for Qualified Nonelective and Qualified Matching Contributions
05/18/2018 Vesting Schedules for Matching Contributions
05/18/2018 Qualification Requirements for Non-Electing Church Plans under IRC Section 401(a)
05/18/2018 Borrowing Limits for Participants with Multiple Plan Loans
05/18/2018 Treatment of 401(a)(17) Limitation in Defined Contribution Plan in a Short Plan Year
05/18/2018 Treatment of 415(c) Dollar Limitations in a Short Limitation Year
05/30/2018 How to Change Interest Crediting Rates in a Cash Balance Plan
05/30/2018 Spousal Consent Period to Use an Accrued Benefit as Security for Loans
03/14/2019 Preventing the Occurrence of a Nonallocation Year under IRC Section 409(p)
06/26/2019 Hardship Distributions from 401(k) Plans
02/27/2020 Plan Termination: Failure to Timely Distribute Assets
03/11/2020 Design-based Safe Harbor Plan Compensation
03/11/2020 Plan Loan Cure Period

Federal, State & Local Government

Date Title
02/18/2016 Employers Must Withhold FICA Taxes for Aliens who Change Visa status to H-1B
04/26/2016 Totalization Agreements
05/03/2016 Qualified Parking Fringe Benefit
09/13/2016 Excise tax on Specified Federal Foreign Procurement Payments
12/16/2016 Taxpayer Identification Matching (TIN) Tools
06/01/2017 Third Party Payer Arrangements – Section 3504 Agents
09/10/2017 Student FICA Exception
09/11/2017 Worker Reclassification – Section 530 Relief
09/11/2017 Third Party Payer Arrangements – Payroll Service Providers and Reporting Agents
01/25/2018 Common Paymaster
03/23/2018 Section 530 Relief for Governmental Entities
10/02/2019  Third Party Payer Arrangements – Professional Employer Organizations
10/03/2019 Qualified Tuition Reduction 

Indian Tribal Governments

Date Title
04/10/2018 IRC Section 7871 – Treatment of Indian Tribes as States

IRC Section 7873 – Treaty Fishing Rights-Related Income

06/11/2018 IRC Section 414(d) – Governmental Plans for Tribes
06/11/2018 Revenue Ruling 59-354 – Tribal Council Members’ Wages
06/11/2018 FUTA Exemption for Indian Tribal Governments
05/21/2019 Per Capita Distributions on Net Gaming Profits and the Kiddie Tax
06/27/2019 Availability of the Work Opportunity Tax Credit to Tribes and Tribal Entities
12/17/2019 Impact of the Tribal Social Security Fairness Act on Worker Status for Tribal Council Members

Tax Exempt Bonds

Date Title
06/24/2016 95% Expenditure Requirement for Exempt Facility Bonds
06/24/2016 Requirement to Spend Available Project Proceeds of Qualified Tax Credit Bonds within 3 Years of Date of Issuance
09/13/2017 Bonds with a Qualified Hedge – Hedge Termination
09/13/2017 Sale or Disposition of a Bond Financed IRC Section 501(c)(3) Facility
10/05/2017 Qualified Residential Rental Property – Multifamily Housing Bonds
11/7/2017 Maturity Limitation for Certain Private Activity Bonds
01/29/2018 Determining if a Guaranteed Investment Contract was Purchased at Fair Market Value
03/22/2018 Recovery Zone Bonds, Clean Renewable Energy Bonds, Qualified Tax Credit Bonds and Tribal Economic Development Bonds Volume Cap (National Limitation)
04/12/2018 Rebate & Yield Reduction: Required Payment Dates for Interim Computation Dates
04/12/2018 Rebate & Yield Reduction: Next Required Computation Date
04/12/2018 Rebate & Yield Reduction: Use of Interim Computation Dates in Late Rebate Calculations
06/15/2018 "Deep Discount": Effect on Exempt Facility Bonds Compliance
06/29/2018 Universal Cap under Treasury Regulation Section 1.148-6(b)(2)
07/16/2018 Qualified Mortgage Bonds – Current Refunding/ Replacement Refunding Structure
07/27/2018 Excess Costs of Issuance for Private Activity Bonds
10/31/2018 Advance Refunding Bond Limitations Under Internal Revenue Code Section 149(d)
11/09/2018 Private Business Use – Management Contracts
11/20/2018 Private Business Use – Federal Use of Tax-Exempt Financed Prison Facilities
11/05/2019 Rehabilitation Requirement under IRC Section 147(d) for Financing Acquisitions of Existing Property

NOTE: Issue Snapshots are not official pronouncements of law or directives and cannot be used, cited or relied upon as such. Issue Snapshots provide an overview of an issue and are a means for collaborating and sharing knowledge among IRS employees. Issue Snapshots may not contain a comprehensive discussion of all pertinent issues, law or the IRS's interpretation of current law. Issue Snapshots do not limit an IRS examiner’s ability to use other approaches when examining issues. Issue Snapshots and any non-precedential material (e.g., a private letter ruling, determination letter, or Chief Counsel advice) that may be referenced in an Issue Snapshots may not be used or cited as precedent. References to third party service providers and documents, like news or journal articles, are for informational purposes only and do not constitute an endorsement of any vendor, document, or the services or views offered by such third party.To provide feedback on a specific Issue Snapshot, please send an email to and specify the Issue Snapshot’s name. Please do not reference a specific individual or entity in your email as comments may be subject to future release. The IRS does not commit to respond to suggestions or comments.