These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.
This notice of proposed rulemaking modernizes regulations regarding the sale of a taxpayer’s property that the IRS seizes by levy. The proposed amendments would allow the IRS to maximize sale proceeds for the benefit of the taxpayer whose property the IRS has seized and the public fisc and would affect all sales of property the IRS seizes by levy.
These final regulations under section 509(a)(3) address the requirements for section 501(c)(3) organizations to qualify as public charities when they are operated, supervised or controlled by one or more supported organizations (Type I Supporting Organizations) and when they are operated in connection with one or more supported organizations (Type III Supporting Organizations). These final regulations provide rules for qualifying as functionally integrated and non-functionally integrated Type III Supporting Organizations. These final regulations also provide rules for the prohibition on certain contributions to Type I and Type III supporting organizations.
26 CFR 1.509(a)-4: Supporting Organizations
Treasury Regulation §1.367(b)-10 requires corporations that acquire parent stock or securities in exchange for property in connection with certain triangular reorganizations to make adjustments that have the effect of a distribution of property. The proposed regulations set forth additional rules that apply to a subsequent inbound nonrecognition transaction in cases where those adjustments are not made.
This notice grants relief under § 7508A of the Internal Revenue Code to taxpayers affected by the October 7, 2023 terrorist attacks in the State of Israel. The notice postpones deadlines for certain time-sensitive taxpayer and government acts for affected taxpayers for a full year, until October 7, 2024. The covered area receiving relief under this notice includes the State of Israel, the West Bank and Gaza. The notice also identifies categories of affected taxpayers and provides a non-exhaustive list of the acts postponed.
The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.