Internal Revenue Bulletin: 2014-2
January 6, 2014
Under interim guidance, a Type III supporting organization will be treated as functionally integrated if it (i) supports a supported organization that is a governmental entity to which the supporting organization is responsive; and (ii) engages in activities for or on behalf of that governmental supported organization that perform the functions of, or carry out the purposes of, that governmental supported organization and that, but for the involvement of the supporting organization, would normally be engaged in by the governmental supported organization itself. Pending further guidance, private foundations and sponsoring organizations that maintain donor-advised funds generally may continue to rely on the grantor reliance standards of Notice 2006–109, as modified by this notice, in determining whether a potential grantee is a Type I, Type II, or functionally integrated Type III SO for purposes of the excise taxes imposed under sections 4942, 4945, and 4966. Comments are requested by March 7, 2014. Notice 2006–109 modified.
This document sets forth procedures for issuing determination letters and rulings on the exempt status of organizations under sections 501 and 521 of the Code. The procedures also apply to revocation and modification of determination letters or rulings, and provide guidance on the exhaustion of administrative remedies for purposes of declaratory judgment under section 7428 of the Code. Rev. Proc. 2013–9 is superseded.
This document sets forth procedures for issuing determination letters and rulings on private foundation status under section 509(a) of the Code, operating foundation status under section 4942(j)(3), and exempt operating foundation status under section 4940(d)(2), of organizations exempt from Federal income tax under section 501(c)(3). This revenue procedure also applies to the issuance of determination letters on the foundation status under section 509(a)(3) of nonexempt charitable trusts described in section 4947(a)(1). Rev. Proc. 2013–10 is superseded.
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