美国国税局免税和政府实体新的合规计划

每年, the 税-Exempt and 政府 Entities division (TEGE) of the Internal Revenue Service (IRS) issues a letter stating its priorities as part of the IRS’s 2023-2031 Strategic Operating Plan. 

Along with the annual letter, the IRS posts new compliance program initiatives as they are launched.  2024财政年度, the TEGE Compliance Governance Board has issued new compliance programs for 税-exempt hospitals as well as 税-exempt collectives using name, 图像, 以及与学生运动员的相似协议.  TEGE will also be continuing compliance with Section 4960 excise 税. 

The IRS is focusing on verifying whether 税-exempt hospitals are in compliance with IRC Section 501(c)(3), including the community benefit standard as well as IRC Section 501(r).  是由病人保护和平价医疗法案带来的, Section 501(r) requires 税-exempt hospital organizations to establish financial assistance and emergency medical care policies; limit the amounts charged to individuals eligible for assistance under the hospital’s financial assistance program (FAP); and make reasonable efforts to determine an individual’s eligibility under the hospital’s FAP before engaging in extraordinary collection actions.  The strategy that the IRS will employ for verification is examinations. 

在最高法院的NCAA诉. 阿尔斯顿2021年裁决, NCAA实施了一个名字, 图像, 和样式 (NIL) policy which permits student-athletes to earn compensation for the use of their name, 图像, 和样式.  税-exempt organizations that identify as supporting athletes using NIL for compensation must disclose their activities in their application for exemption.  They must show that those activities are in full compliance with existing legal requirements under 501(a). The strategy that the IRS will employ for verification is examinations. 

包括在减税和就业法案中, Section 4960 imposes a 21% excise 税 on 税-exempt organizations that pay over $1 million in compensation to any “covered employee.”  A covered employee is defined as “one of the five highest compensated employees of the organization for the 税able year” or “was a covered employee of the organization (or any predecessor) for any preceding 税able year beginning after December 31, 2016.”  The IRS’s ongoing review of filing data shows that there is a high volume of exempt organizations that were required to report the excise 税 on Form 4720, Return of Certain 特许权 税es Under Chapters 41 and 42 of the Internal Revenue Code, 但未能如愿.  The IRS’s strategies to be employed to ensure that Section 4960 is being followed are compliance checks and examinations of Form 4720.

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