Listed below is a series of articles published as the Exempt Organizations Continuing Professional Education (CPE) Technical Instruction Program for Fiscal Year 1983. The 1983 series of articles were published in January 1983. These materials were designed specifically for training purposes only. Under no circumstances should the contents of these articles be used or cited as authority for setting or sustaining a technical position. The freely available Adobe Acrobat Reader software is required to view, print and search these files. Outlook on Churches and Religious and Apostolic Organizations PDF A discussion of churches and other religious organizations, including apostolic organizations. Update on Private Schools PDF A discussion of legislative and administrative developments relating to the exemption of private schools, and the treatment of day care centers, under IRC 501(c)(3). Health Care Organizations PDF A discussion of hospital reorganization issues. Inurement PDF A discussion of the inurement principle as it relates to exemption from federal income tax, with particular attention to inurement arising from excessive compensation, conversion of a for-profit organization to non-profit, and home health agencies. Recent Developments in the Interpretation of Final Regulations under IRC 501(c)(9) Voluntary Employees' Beneficiary Association PDF Issues in interpreting final section 501(c)(9) regulations, including the definition of geographic locale, definition of affiliated employers, permissibility of membership restrictions, restrictions on eligibility for benefits, permissible benefits, and inter-VEBA transfers. IRC 502 - Feeder Organizations PDF A discussion of basic issues relating to feeder issues under IRC 502, and consideration of the amount of unrelated business activity in which an exempt organization may engage. IRC 4943 - Transitional Rules and Other Current Topics PDF A brief review of IRC 4943, and discussion of transitional rules and other current topics. Current Developments in IRC 4945 - Educational Grants to Individuals PDF Developments relating to educational grants to individuals, including scholarships restricted to particular groups, company scholarship questions, other employee preference programs, grants to related parties, and the availability of discretionary relief under IRC 7805(b). A General Explanation of Trusts Subject to IRC 4947 PDF General explanation of trusts subject to IRC section 4947, including nonexempt charitable trusts under section 4947(a)(1) and split interest trusts under section 4947(a)(2). Statute of Limitations for Exempt Organizations Returns PDF A clarification of two issues addressed in the 1982 article on the same topic. IRC 6110 - Public Inspection of Written Determinations PDF Public inspection of written determinations under IRC 6110, and the procedures for processing determinations and rulings subject to that provision. Domestic Organizations with Foreign Operations PDF Treatment of domestic charitable organizations with foreign operations, focusing on exemption under IRC 501(c)(3); foundation status under IRC 509; deductibility of contributions, bequests, and gifts under IRC 170, 2055, and 2522; and treatment of domestic foundations making grants to foreign organizations.
