This table represents the July 24, 2013 status of recommended actions from the Treasury Inspector General for Tax Administration’s (TIGTA) report on IRS’s tax-exempt area. Exempt Organizations Recommended Actions Ending July 24, 2013 No. Recommendation Lead ECD Status* Actions Taken 1 Ensure that the memorandum requiring the Director, Rulings and Agreements, to approve all original entries and changes to criteria included on the BOLO listing prior to implementation be formalized in the appropriate Internal Revenue Manual. Director, Exempt Organizations 06/28/2013 09/30/2013 Completed Because the use of the BOLO lists was suspended (reported in June), the memorandum is no longer operational therefore we are closing this recommendation. However, separately, we are revising the IRM that provides guidance on processing exempt application and have incorporated into the draft comments received from the Taxpayer Advocate and providing training to staff on how to apply appropriate screening criteria. 2 Develop procedures to better document the reason(s) applications are chosen for review by the team of specialists (e.g., evidence of specific political campaign intervention in the application file or specific reasons the EO function may have for choosing to review the application further based on past experience). Director, Exempt Organizations 09/30/2013 Green Team is completing in-depth review into classification and screening process beginning the week of July 22, 2013 and will begin development of procedures. 3 Develop training or workshops to be held before each election cycle including, but not limited to, the proper ways to identify applications that require review of political campaign intervention activities. Director, Exempt Organizations 01/31/2014 Green Project team consisting of Subject Matter Experts and Learning and Education members was identified. Two meetings were held to determine specific scope of training materials and identify necessary tasks for implementation. 4 Develop a process for the Determinations Unit to formally request assistance from the Technical Unit and the Guidance Unit. The process should include actions to initiate, track, and monitor requests for assistance to ensure that requests are responded to timely. Director, Exempt Organizations 06/28/2013 01/31/2014 Completed The new process is documented in written procedures, which enables the use of a spreadsheet-based tracking tool. We are closing this recommendation as the required actions have been completed. However, IRS will expand its efforts through development of a long-term plan. 5 Develop guidance for specialists on how to process requests for tax-exempt status involving potentially significant political campaign intervention. This guidance should also be posted to the Internet to provide transparency to organizations on the application process. Director, Exempt Organizations 06/27/2013 01/31/2014 Green EO leadership and EO Determinations, in consultation with staff of the office of the Division Counsel/Associate Chief Counsel (TE/GE), are beginning development of an action plan for addressing additional pending cases and future applications involving tax-exempt status. 6 Develop training or workshops to be held before each election cycle including, but not limited to: a) what constitutes political campaign intervention versus general advocacy (including case examples) and b) the ability to refer for follow-up those organizations that may conduct activities in a future year which may cause them to lose their tax-exempt status. Director, Exempt Organizations 01/31/2014 Green Project team consisting of Subject Matter Experts and Learning and Education members was identified. Two meetings were held to determine specific scope of training materials and identify necessary tasks for implementation. 7 Provide oversight to ensure that potential political cases, some of which have been in process for three years, are approved or denied expeditiously. Director, Exempt Organizations 01/31/2014 Green As of July 18, 2013, will have closed 37 cases in original backlog (28%). As of July 18, 2013, 82 letters were issued for applicants to self-certify under the expedited process. To date, 10 favorable determination letters have gone to applicants participating in the optional expedited process. EO leadership and EO Determinations, in consultation with staff of the Office of Chief Counsel (TE/GE), are beginning development of an action plan for addressing additional pending cases and future applications involving tax-exempt status. 8 Recommend to IRS Chief Counsel and the Department of the Treasury that guidance on how to measure the “primary activity” of I.R.C. § 501(c)(4) social welfare organizations be included for consideration in the Department of the Treasury Priority Guidance Plan. Commissioner, Tax Exempt and Government Entities 05/03/2013 Completed Recommendation closed June 2013. On May 7, 2013, EO representatives discussed (c)(4) recommendation with TE/GE Counsel and Treasury Office of Tax Policy. Treasury agreed to include these items in the next Priority Guidance Plan. 9 The Director, EO, should develop training or workshops to be held before each election cycle including, but not limited to, how to word questions in additional information request letters and what additional information should be requested. Director, Exempt Organizations 01/31/2014 Green Project team consisting of Subject Matter Experts and Learning and Education members was identified. Two meetings were held to determine specific scope of training materials and identify necessary tasks for implementation. *Green = On schedule, Yellow = Behind schedule, Red = Significant issues
