Weekly Reader – January 10, 2014

Top reads we’re reading this week.


IRS Removes Expedited Handling for Determination Letters (NonprofitLawMatters.com)

In Section 9.03(3) of the new Revenue Procedure 2014-4, the IRS has clarified that the option to request expedited handling is no longer available for determination letters.  The Revenue Procedure defines a “determination letter” as “a written statement issued to a taxpayer by the Service’s [Exempt Organization] Determinations or [Employee Plan] Determinations office that applies the principles and precedents previously announced to a specific set of facts.”  In the EO context, determination letters are issued on a variety of matters, including:

  • to determine an organization’s initial qualification for tax-exempt status under Section 501;
  • to update an exempt status letter or replace a lost one;
  • to make a determination about the classification, reclassification, or termination of private-foundation status;
  • to classify a supporting organization under Section 509(a)(3) of the Internal Revenue Code.

The Revenue Procedure has a full list of the matters covered by EO determination letters in Section 7.04.  Expedited handling is apparently still available for letter ruling requests.


Philanthropy can’t wish its way out of inequality (DailyWRAG.com)

Unconscious Bias

“We can’t volunteer our way out of this, we can’t charity our way out of this, we can’t wish our way out of this.”

That was Dr. Gail Christopher’s message for WRAG members at a recent program on unconscious bias. “The work of creating opportunity for all is far from done,” she said. But nothing short of a transformation in how we relate to one another will allow our nation to truly become a place in which there is equal opportunity for all.

According to Dr. Christopher, who heads the America Healing initiative at the W.K. Kellogg Foundation, this starts with an understanding that centuries of racial injustices created inequities that persist today. While the laws that sanctioned segregation are gone, racism continues to exist, often manifesting itself in subtle and often unconscious ways.


Think You Know Private Foundations? Think Again. (Stanford Social Innovation Review, SSIReview.org)

The reality is that most people, including reporters, attorneys, wealth managers, and other professionals who engage with the philanthropic sector, know about private foundations only from studies, surveys, and press coverage focused on the largest two percent of private foundations—those with hundreds of millions of dollars. As a result, our understanding of what private foundations are and how they behave is dramatically skewed.



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