Tax-Exempt & Government Entities (TE/GE): Completed compliance strategies

This strategy verified IRC Section 501(c)(3) charitable organizations that previously operated as for-profit businesses were operating in a charitable manner as an exempt organization and not providing impermissible private benefit or inurement that, if substantial, could be basis for revocation of exempt status.

Workstream: Examination 

This strategy identified primary and related returns that indicated operational issues with loans to disqualified persons that could result in assessment of excise tax sanctions and revocation of exempt status.

Workstream: Examination

This strategy sought to identify, contact, and bring suspected non-compliant NECTs into compliance with their filing requirements and reporting/paying excise and/or income taxes.

Workstreams: Examination and Compliance Checks  

This strategy addressed the 85%-member income requirement for IRC 501(c)(12) organizations.

Workstreams: Compliance Checks and Educational Letter (Letter 4204)

This strategy addressed whether IRC 509(a)(3) organizations were erroneously filing F990-N.

Workstream: Educational Letter (Letter 6194) 

This strategy identified IRC 501(c)(7) organizations that exceeded non-member and investment limitations and considered revocation of exempt status of those that continually exceeded limitations.

Workstreams: Examination, Compliance Check, and Educational Letter (Letter 6176) 

This strategy secured delinquent Form 990-Ts for organizations that reported gaming income from pull tabs, instant bingo, and/or progressive bingo on Forms 990/990-EZ.

Workstream: Compliance Check

This strategy sought to secure delinquent and amended Forms 990-T for state-chartered credit unions that failed to report UBI for non-member automated teller machine (ATM) fees, and accidental death and dismemberment (AD&D), automobile, and property and casualty (homeowners) insurance.

Workstream: Compliance Checks 

This strategy was a follow-up letter issuance intended to allow analysis with prior results to determine if organizations remained in compliance with the disclosure requirements for non-deductible contributions.

Workstream: Educational Letter (Letter 6194) 

This strategy sought to educate taxpayers on IRC 501(c)(19) membership requirements and consequences of failure to meet the membership test.

Workstream: Educational Letter (Letter 6194) 

This strategy examined Form 990-Ts from hospitals that reported losses in computing taxable UBI.

Workstream: Examination

This strategy sought to resolve the delinquency where an exempt organization reported wages on Forms W-2 but failed to file Form 940.

Workstream: Compliance Check 

This strategy determined eligibility of an exempt organization to use Form 990-N, Electronic Notice (e-Postcard).

Workstream: Examination

This strategy reviewed SEP-IRA plan participants that failed to take the RMD under Section 401(a)(9) of the Internal Revenue Code (IRC).

Workstreams: Examination and Compliance Check 

This strategy examined whether oil and gas extraction industry plans paid the correct amount and form of benefits to their employees in a timely manner.

Workstream: Examination 

This strategy examined whether petroleum industry plans paid the correct amount and form of benefits to their employees in a timely manner.

Workstream: Examination

This strategy addressed plans missing required actuarial information on their Form 5500 series return.

Workstream: Compliance Check 

This strategy addressed whether plan sponsors accurately reported non-participant loans as “other loans,” including type of transaction and accurate dollar amount (fair market value).

Workstream: Compliance Check 

This strategy addressed compliance issues within controlled groups of businesses that may not have met coverage requirements of group SEP IRA plan offerings.

Workstreams: Examination, Compliance Check, and Educational Letter (Letter 6194) 

This strategy addressed possible indirect service requirements in violation of IRC 410(a).

Workstream: Compliance Check 

This strategy addressed possible violations and deduction issues in small defined benefit plans with large assets.

Workstream: Examination

This strategy identified and resolved issues such as prohibited transactions, asset valuation and related funding issues, and potential fiduciary violations that may arise with third-party loans.

Workstream: Examination 

This strategy addressed unpaid required minimum funding amounts (funding deficiencies) and delinquent Form 5330 returns related to excise tax.

Workstream: Compliance Check 

This strategy reviewed Forms 5500 and 5500-SF filings to identify plans with filing requirements that failed to file.

Workstreams: Examination and Compliance Check 

This strategy educated top-heavy plan sponsors on resolving minimum contribution compliance issues using the Voluntary Compliance Program.

Workstream: Educational Letter (Letter 6194) 

This strategy identified Form 5500 series returns with missing or incorrect codes, verified IRS system information, and provided education to the return filer.

Workstream: Compliance Check 

This strategy secured delinquent/amended returns from sponsors filing their first Form 5500-EZ with beginning of the plan year trust assets greater than $250,000.

Workstream: Compliance Check 

This strategy determined completion and accuracy of financial information on Form 5500 series returns.

Workstream: Compliance Check

This strategy addressed plans that appeared to have experienced a partial termination and informed plan sponsors of full vesting requirements.

Workstreams: Compliance Check and Educational Letter (Letter 1562-Z)

This strategy addressed concerns from a U.S. Treasury Inspector General for Tax Administration (TIGTA) report related to monitoring 401(k) plans for excess contributions.

Workstream: Newsletter

This strategy reviewed plans with a filing requirement and no final return filed, that previously filed Form 5500-EZ.

Workstream: Compliance Check 

This strategy verified the sponsoring employer’s eligibility to maintain a SIMPLE IRA and correct non-compliant plans.

Workstream: Compliance Check

This strategy investigated excess contributions reported on Forms W-2 and evaluated whether employers correctly calculated contributions and applied plan limits.

Workstream: Compliance Check

This strategy addressed possible prohibited transactions and deemed distributions with participant loans reported on Form 5500, Schedule I, Form 5500-SF, and Form 5500-EZ.

Workstream: Examination

This strategy identified non-compliance in SIMPLE IRA plans with apparent plan eligibility and/or incorrect employer contributions.

Workstream: Examination 

This cross-functional strategy between Employment Tax and Employee Plans identified examined cases with worker classification issues and verified proper coverage by the employer’s retirement plans.

Workstream: Examination

This strategy sought to improve compliance with the income and FICA taxation of ERIPs.

Workstreams: Examination and Issue Snapshot 

This strategy addressed the proper characterization of Form 1099-MISC payments to workers that received both a Form W-2 and a Form 1099-MISC/NEC from the employer.

Workstreams: Examination and Issue Snapshot

This strategy sought to address substantial non-compliance with backup withholding requirements related to CP2100 Notices.

Workstreams: Examination, Industry Outreach, and Practitioner Outreach 

This strategy determined compliant application of certain fringe benefits, to include proper taxation and reporting. Benefits included accountable plans, employer-provided vehicles, employer-provided clothing, meals while not in travel status, and travel.

Workstreams: Examination, Compliance Check, and Educational Letter (Letter 6194)

This strategy determined TE/GE taxpayer compliance for those taxpayers that filed more than fifty (50) Forms 1099-MISC one year but did not file any the following tax year.

Workstream: Compliance Check 

This strategy secured delinquent, unfiled employment tax returns including Forms 941, 944, 943, and CT-1 where Forms W-2 were filed.

Workstream: Compliance Check

This strategy secured unfiled Form 945 tax returns from TE/GE taxpayers that filed information returns and reported federal tax withholding but did not file the required Form 945 to report the taxes withheld.

Workstream: Compliance Check

This strategy determined whether the rehabilitation requirement was met for the acquisition of existing property.

Workstreams: Examination and Issue Snapshot 

This strategy developed remedial actions that could be taken by issuers of tax-advantaged bonds to preserve tax-advantaged status when failing to timely invest escrow proceeds in 0% State and Local Government Series.

Workstream: N/A

This strategy examined bond issuances where the issuer took remedial actions to ensure they met all requirements under the applicable regulations and for the development of a Notice or other documentation to be included in a Notice of Defeasance.

Workstream: Examination

This strategy addressed a potential violation resulting from private activity bond proceeds greater than 2% being used to pay costs of issuance of the issue.

Workstreams: Examination and Issue Snapshot 

This strategy addressed possible arbitrage violations resulting from investment of proceeds of variable rate bonds.

Workstreams: Examination and Issue Snapshot

This strategy identified correctional facilities financed with tax-exempt bonds for non-compliance relating to private business use violations.

Workstreams: Examination and Issue Snapshot

This strategy concerned potential violations of the special rule for sinking (or reserve) funds associated with certain tax credit bonds.

Workstream: Examination 

This strategy focused on violations of the prohibition on tax-exempt advance refundings.

Workstream: Compliance Check