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November 14,  2008

Federal Headlines


IRS Issues Guidance to REITS on How to Apply Prohibited Transactions Tax Safe Harbor (Rev. Proc. 2008-69)

 

The IRS has provided real estate investment trusts (REITS) with a method for applying the prohibited transactions tax safe harbor under Code Sec. 857(b)(6))(C)(iii) and (D)(iv) for a tax year that begins on or before July 30, 2008, and ends on or after July 31, 2008. The requirements are satisfied if either: (1) the REIT satisfies the 7-Sales Test for the entire tax year or (2) the REIT satisfies the 10-Percent Adjusted Basis Test.

 

The requirements are also satisfied if both: (1) the aggregate adjusted bases (as determined for purposes of computing earnings and profits) or property (other than sales of foreclosure property or sales to which Code Sec. 1033 applies) sold during the portion of the tax year ending on July 30, 2008, did not exceed 10 percent of the aggregate bases of all of the assets of the REIT as of the beginning of the tax year and (2) the REIT satisfies the 10-Percent Fair Market Value Test for the entire tax year.

Rev. Proc. 2008-69, 2008FED ¶46,648

Other References:

 

Code Sec. 857

 

CCH Reference - 2008FED ¶26,533.55

 

Tax Research Consultant

 

CCH Reference - TRC RIC: 6,070.05


IRS Issues Guidance on Applicable Percentage Floor for Low Income Housing Credit (Notice 2008-106)

 

The new 9 percent applicable percentage floor for non-Federally subsidized new buildings that are placed in service after July 30, 2008, and before December 31, 2013, enacted under section 3002(a)(1) of the Housing Assistance Tax Act of 2008 (P.L. 110-289), applies even if the taxpayer made a prior irrevocable election on or before July 30, 2008, to apply an applicable percentage that is less than 9 percent. Despite the 9 percent applicable percentage floor, the housing credit dollar amount allocated to a project shall not exceed the amount the housing credit agency determines is necessary for the financial feasibility of the project and its viability as a qualified low-income housing project throughout the credit period.

Notice 2008-106, 2008FED ¶46,649

Other References:

 

Code Sec. 42

 

CCH Reference - 2008FED ¶4385.025

 

CCH Reference - 2008FED ¶4385.45

 

Tax Research Consultant

 

CCH Reference - TRC BUSEXP: 54,214

 


IRS Warns Against Charities' Usage of More Aggressive Tactics in Response to Cutbacks in Giving

 

Despite the economic slowdown, charitable organizations should not take more aggressive postures to solicit donations, Ronald J. Schultz, senior technical advisor, IRS Tax Exempt and Government Entities (TE/GE) Division, warned on November 13. Schultz said that the Service will be watching for fund-raising and valuation abuses. In other news, Schultz said that the long-awaited final version of Form 990, Return of Organization Exempt from Income Tax, will be released in the near future. Schultz spoke at a conference on tax-exempt organizations sponsored by the American Law Institute --American Bar Association (ALI-ABA) in Washington, D.C.

Exempt Organizations

 

"We will be looking for behavioral changes in the (tax-exempt) sector," Schultz said. Many charities and exempt organizations are expecting a downturn in giving as consumers tighten their wallets during the recession. The drop in contributions may be particularly notable during the upcoming holiday season.

 

Schultz cautioned that some charities may be tempted to enter into "questionable" deals or become more willing to cut corners in their fund-raising activities. Noncash contributions are especially ripe for abuse. "Noncash donations can have serious valuation issues," he noted.

 

Monica Stern, CPA, Phoenix, Ariz., told CCH that she expects to see fewer donations of stocks this year because of the downturn in the financial markets. The financial crisis will also discourage distributions from IRAs to charitable organizations, despite the recent extension of this tax incentive in the Emergency Economic Stabilization Act of 2008 (P.L. 110-343). "IRA donations will likely be down as taxpayers see their account balances fall." Stern also cautioned that some taxpayers may seek over-inflated appraisals of real property.

Form 990

 

The IRS remains "on track" to release the final version of Form 990 and its instructions by mid-November, Schultz said. "Form 990-EZ and its instructions will also be out at the same time." Schultz added that tax-exempts and practitioners can expect to see no material changes in content from draft versions of Form 990, which have been posted on the agency's web site for comment (TAXDAY, 2008/11/05, I.1).

 

Schultz reported that the IRS has received requests to redesign Form 990-PF, Return of Private Foundation, but stated "A Form 990-PF redesign is not realistic at this time." Budget and personnel constraints appear to stand in the way. However, Schultz did say that the Service could explore adding a Schedule PF to the new Form 990.

Colleges and Universities

 

In October, the IRS sent questionnaires to approximately 400 private and public colleges and universities (IR-2008-112; TAXDAY, 2008/10/02, I.2). The IRS is requesting information on how colleges and universities classify their activities as exempt or taxable, how they calculate and report income or losses on taxable activities and how they invest and use endowment funds. "There are numerous questions on executive compensation," Schultz said.

 

According to Schultz, the IRS intends to issue an interim report on this study in 2009. "We may address questions from the college and university sector with Frequently Asked Questions (FAQs)," he added.

 

By George L. Yaksick, Jr., CCH News Staff


State Headlines


Missouri --Insurance Premium Tax: Refund Requests Were Untimely

 

Out-of-state insurance companies that did business in Missouri and paid a tax on the insurance premiums they collected in Missouri did not timely file tax refund requests for their 2004 insurance premium tax payments. Under Sec. 136.035.3, RSMo, the general tax refund statute, the deadline for the insurers' 2004 premium tax refund claims was two years from the date the insurers remitted their final 2004 premium taxes, or June 2, 2007. The insurers contended that Sec. 148.076, not Sec. 136.035, established the statute of limitations for their refund requests because it was in the same chapter as the statute that imposes the insurance premium tax. However, the insurers' argument was unpersuasive because Sec. 148.076, by its plain language, is limited to refunds of overpayments of taxes imposed pursuant to specific statutory provisions relating to banking institutions.

 

The insurers' refund requests were postmarked Friday, June 1, 2007. Delivery of the refund requests was attempted on June 2, but the director of revenue's office was closed because it was a Saturday. The refund requests were received by the director's office when it reopened for business on Monday, June 4. Sec. 136.035 does not mandate that the tax refund request deadline be extended if it falls on a Saturday, and the Legislature has not created a general exception for statutory deadlines that fall on a Saturday. In addition, there is no statute requiring the director of revenue to accept physically delivered Sec. 136.035 filings on a Saturday. Thus when the refund request deadline under Sec. 136.035.3 falls on a Saturday, the de facto deadline for filings is the preceding business day.

 

The insurers cited Evergreen Lawn Service, Inc. v. Director of Revenue, 685 S.W.2d 829 (Mo. banc 1985), for the proposition that their refund requests were timely filed because they attempted physical delivery on the closed director's office on the statutory deadline of June 2, 2007. However, the insurers' reliance on Evergreen was misplaced. Evergreen pertained to the statutory time limitation on appeals to the Missouri Administrative Hearing Commission, not on refund requests lodged with the director of revenue. In contrast, the insurers in this case challenged the time limitation for retrieving money from the state's treasury. Unlike provisions governing the right to an appeal, tax refund provisions are strictly construed against the taxpayers. Accordingly, the court could not rewrite Sec. 136.035 to extend the applicable statute of limitations or to permit extended time for filing refund requests.

Insurance Co. of the State of PA v. Director of Revenue, Missouri Supreme Court, No. SC89080, November 4, 2008, ¶203-018

 

Other References:

 

Explanations at ¶89-224


Oregon --Motor Fuel Tax: Progressive Vehicle Fees, Gas Tax Increase Proposed by Governor

 

Oregon Gov. Ted Kulongoski proposed a new transportation infrastructure plan that would raise an estimated $500 million annually through a combination of progressive vehicle registration and title fees and a 2-cent increase in the gas tax. The governor's plan --The Jobs and Transportation Act of 2009 --also included changes to the state's tax incentives for alternative energy vehicles to reflect changes in technology. In announcing the plan, Gov. Kulongoski expressed flexibility on the proposed gas tax increase and the need to find a long-term replacement for the gas tax as a transportation funding source. The governor's press release can be located at http://governor.oregon.gov/Gov/P2008/press_111008.shtml.

Press Release, Gov. Ted Kulongoski, November 10, 2008; Governor's Comments to Oregon House and Senate Transportation Committees, November 10, 2008

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