Finance Committee Democratic Staff

Summary of Joint Committee on Taxation Report on Options to

Improve Tax Compliance and Reform Expenditures

January 27, 2005

(Costs are over 10-year window)

 

 

VIII. EXEMPT ORGANIZATIONS

 

A. Require Five-Year Review of Exempt Status of Public Charities and Private

Foundations and Annual Notice by Organizations Not Required to File Information

Returns (sec. 508). The proposal require that every five (5) years §501(c)(3)

organizations (except Houses of Worship), must file with the Secretary information on

whether it continues to be organized and operated exclusively for exempt purposes. This

filing must be done electronically and made publicly available. Failure to file would

result in loss of tax-exempt status. Raises: Less than $50 million

 

B. Impose Termination Tax on Conversions of Assets of Charities (sec. 501, 507,

4941, and 4958). The proposal applies to public charities and to private foundations, and

thus eliminates the present- law aggregate tax benefit limit contained in §507. In the case

of private foundations, the proposed termination tax applies to voluntary or involuntary

terminations, as well as to conversion liquidation transactions. The proposed termination

tax also applies to a public charity if there have been either willful repeated acts or

failures to act that give rise to liability for Chapter 42 taxes, which includes §§ 4955 and

4958. In order to assure that fair consideration is paid in conversion transactions, the

proposal extends the §4958 excess benefit transaction tax rules (in case of public charity)

or §4941 self-dealing rules (in case of a private foundation) to an acquirer of the charity’s

assets in a conversion or liquidation transaction, if persons who are disqualified persons

of the charitable organization are in a position to exercise substantial influence over the

affairs of the acquirer at the time of or after the transaction. No Revenue Effect

 

C. Tax Involvement by Exempt Organizations in Tax-Shelter Transactions (secs.

6011 and 6707A). The proposal requires disclosure by tax exempt entities (often

accommodating parties) to the IRS of participation in a “prohibited tax shelter

transaction” and disclosure of other known parties if it is a reportable transaction.

Prohibited transactions include only certain reportable transactions. New penalties at

both the entity level and the entity manager level are included in the proposal, and the

deductibility of contributions to the entity may be suspended for one year. Existing

disclosure penalties also apply. Raises: $500 million

 

D. Reform Intermediate Sanctions and Extend Certain Reforms to Private

Foundations (secs. 4941 and 4958). Proposal eliminates rebuttable presumption and

establishes due diligence procedures that apply to public charities and private

foundations. If an initial tax is imposed on a disqualified person under the intermediate

sanctions rules or on a self-dealer under the self-dealing rules, the organization is subject

to an excise tax equal to 10% of the excess benefit in the case of a public charity or a

social welfare organization, or 2.5% of the amount involved in the case of a private

foundation. Raises: $200 million


 

E. Increase the Amount of Excise Taxes Imposed on Public Charities, Social

Welfare Organizations, and Private Foundations (secs. 4941, 4942, 4943, 4944, 4945,

and 4958). For acts of self-dealing other than the payment of compensation by a private

foundation to a disqualified person, the initial tax on the self dealer goes from 5% to 10%

of the amount involved. For acts of self-dealing regarding the payment of compensation

by a private foundation to a disqualified person, the initial tax on the self-dealer goes

from 5% to 25% of amount involved with 15% of which is subject to abatement. It

increases the initial tax on foundation managers from 2.5% to 5% of the amount involved

and increases the dollar limitation on the amount of the initial and additional taxes on

foundation managers per act of self-dealing from $10,000 per act to $20,000 per act, and

doubles the dollar limitation on organization managers of public charities and social

welfare organizations for participation in excess benefit transactions from $10,000per

transaction to $20,000 per transaction. Raises: Less than $50 million

 

F. Modify Charitable Deduction for Contributions of Conservation and Façade

Easements (sec. 170). The proposal eliminates the charitable contribution deduction

with respect to façade and conservation easements relating to personal residence

properties, substantially reduces the deduction for all other qualified conservation

contributions, and imposes new standards on appraisals and appraisers regarding the

valuation of such contributions. Raises: $1 billion

 

G. Limit Charitable Deduction for Contributions of Clothing and Household Items

(sec. 170). The proposal limits the amount that taxpayers may deduct for contributions of

clothing and household items to $500. Raises: $1.9 billion

 

H. Reform Rules for Charitable Contributions of Property (sec. 170). Option One:

This proposal contains various options and concepts to limit deductions on donations of

property, generally to the lesser of basis or fair market value. They do not apply to

publicly traded securities and certain other property already addressed in previous

legislation, i.e., intellectual property and vehicles. Suggestions for enhanced appraiser

accountability, limiting the deduction to the disposition amount, and eliminating

deductions for property altogether are also included. Raises: $2.5 billion

 

I. Require Public Disclosure of Form 990-T and Related Certification

Requirements (secs. 6104 and 6685). The proposal extends the present- law public

inspection and disclosure requirements and penalties applicable to the Form 990 to an

organization’s Form 990-T. Organizations that normally have annual total gross

revenues or gross assets of at least $10 million must include with its Forms 990 and 990T

filings a certification by an independent auditor or by an independent counsel. Raises:

Less than $50 million

 

J. Expand the Base of the Tax on Private Foundation Net Investment Income.

Proposal amends the definition of gross investment income to include income from

notional principal contracts, annuities, and other substantially similar income from

ordinary and routine investments. Carrybacks of losses from sales or other dispositions

of property are not included. Raises: $200 million

 


 

K. Limit Tax-Exempt Status of Fraternal Beneficiary Societies that Provide

Commercial-Type Insurance (sec. 501 (c)(8)). A fraternal beneficiary society, order, or

association is exempt from tax as an organization described in section 501(c)(8) only if

no substantial part of its activities consists of providing commercial-type insurance. In

the case of an organization that is exempt from tax under the proposal, it is taxed under

the rules relating to insurance companies rather than under the unrelated business income

tax rules generally applicable to exempt organizations. Raises: $500 million

 

L. Established Additional Exemption Standards for Credit Counseling

Organizations (sec. 501). Under the proposal, a nonprofit credit counseling agency or

other nonprofit organization that provides credit counseling, debt management, and

similar services, is eligible for exemption from income tax only as a charitable or

educational organization under section 501(c)(4). It also provides additional

requirements that must be satisfied by a credit counseling organization in order to be an

organization described in section 501(c)(3) or (c)(4), and the requirements supplement,

rather than replace the present law requirements. Raises: $100 million