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Monday, March 16, 2015
IRS Issues Final 501(c)(29) Application Procedures (Qualified Nonprofit Health Insurance Issuers)
The IRS has issued both final regulations and Revenue Procedure 2015-17 providing the final procedures for issuing determination letters and rulings relating to exemption under Internal Revenue Code section 501(c)(29). Paragraph 29 is the latest addition to section 501(c); it provides a federal income tax exemption for qualified nonprofit health insurance issuers (QNHIIs), also known as CO-OP health insurance insurers, that under the Affordable Care Act receive a loan or grant under the federal Consumer Operated and Oriented Plan Program. The CO-OP Program is designed to foster the creation of these new nonprofits to offer competitive health plans. These health care co-ops have had mixed success, as NPR reported earlier this year that the second largest one in the country recently collapsed.
Additional coverage: Squire Patton Boggs Alert.
March 16, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Friday, March 6, 2015
Newly Revised Publication 557 Issued
The Internal Revenue Service has issued a newly revised Publication 557, Tax-Exempt Status for Your Organization. The beginning "What's New" section lists the following topics: IRS issues new interim guidance for supporting organizations and grantors; New guidance provides transition relief for employee health insurance expenses; Final regulations under section 501(r) issued in December 2014; Correction and disclosure procedures under section 501(r); New Form 1023EZ; Exempt Organizations Division Limited the Types of Cases that Are Referred to Exempt Organizations ("EO") Technical, and Provided for Administrative Review of EO Technical Determinations; and Future developments.
March 6, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Tuesday, February 3, 2015
President's Budget Proposals Affecting Charities
President Obama's proposed Fiscal Year 2016 Budget ("Proposed Budget") contains a few provisions affecting charities and charitably minded donors. The following proposals are of interest. Direct quotes are from either the Proposed Budget or the Department of the Treasury's General Explanations of the Administration's Fiscal Year 2016 Revenue Proposals ("Treasury Explanations"), as indicated.
Limit the Benefit of the Charitable Contributions Deduction
"The Budget would limit the value of most tax deductions and exclusions to 28 cents on the dollar, a limitation that would affect only couples with incomes over about $250,000 (singles with incomes over about $200,000). The limit would apply to all itemized deductions, as well as other tax benefits, such as tax-exempt interest and tax exclusions for retirement contributions and employer-sponsored health insurance." Proposed Budget, 56.
Obviously, the charitable contributions deduction is, as in prior years' budgets proposed by the President, subject to the limitation. According to Treasury Explanations, the provision "would apply to itemized deductions after they have been reduced by the statutory limitation on certain itemized deductions for higher-income taxpayers." Treasury Explanations, 155.
Repeal the Non-Hospital Bond Limitation on Qualified Section 501(c)(3) Bonds
As discussed in Treasury Explanations, "[t]he Tax Reform Act of 1986 established a $150 million limit on the volume of outstanding, non-hospital, tax-exempt section 501(c)(3) bonds. The limit was repealed in 1997 with respect to bonds issued after August 5, 1997, if at least 95 percent of the net proceeds were used to finance capital expenditures incurred after that date. Thus, the limitation continues to apply to bonds more than five percent of the net proceeds of which finance or refinance (1) working capital expenditures, or (2) capital expenditures, incurred on or before August 5, 1997." Treasury Explanations, 77. Treasury believes that the $150 million limitation "results in complexity and provides disparate treatment depending on the nature and timing of bond-financed expenditures," and that repealing it "would enable nonprofit universities to utilize tax-exempt financing on a basis comparable to public universities." Id. Under the administration's proposal, "[t]he $150 million limit on the volume of outstanding, non-hospital, tax-exempt bonds for the benefit of any one section 501(c)(3) organization would be repealed in its entirety, effective for bonds issued after the date of enactment." Id.
Disallow Deduction for Payments Entitling Payor the Right to Buy College Athletics Tickets
As Treasury Explanations notes, "donors to colleges and universities that receive in exchange for their contributions the right to purchase tickets for seating at an athletic event may deduct 80 percent of the contribution." Treasury Explanations, 177. The administration's proposal would disallow a deduction for any such transfer for the right to buy tickets to sporting events. See id.
Consolidate AGI-Based Limitations on Charitable Contributions Deduction
Current law limits the charitable contributions deduction to various percentages of a taxpayer's "contribution base" (basically AGI), depending on the type of charitable donee and the type of donated property. "The proposal would simplify this complicated set of rules limiting deductions for charitable contributions. Under the proposal, the contribution base limit would remain at 50 percent for contributions of cash to public charities. For all other contributions, a single deduction limit of 30 percent of the taxpayer's contribution base would apply, irrespective of the type of property donated, the type of organization receiving the donation, and whether the contribution is to or for the use of the organization. In addition, the proposal would extend the carry-forward period for contributions in excess of these limitations from five to 15 years." Treasury Explanations, 280.
Modify Deduction for Qualified Conservation Contributions
Code section 170 provides special rules for qualified conservation contributions. The administration proposes several modifications to the rules governing the deduction, and also proposes "to pilot a non-refundable credit for conservation easement contributions as an alternative to the conservation contribution deduction …." Treasury Explanations, 191.
Additional details excerpted from Treasury Explanations:
This proposal would make permanent the temporary enhanced incentives for conservation easement contributions that expired on December 31, 2014. In addition, to address concerns regarding abusive uses of this deduction and to promote effective, high-value conservation efforts, the proposal includes a number of reforms:
First, the proposal would strengthen standards for organizations to qualify to receive deductible contributions of conservation easements by requiring such organizations to meet minimum requirements, specified in regulations, which would be based on the experiences and best practices developed in several States and by voluntary accreditation programs. For example, the regulations could, among other things, specify that a "qualified organization" must not be related to the donor or to any person that is or has been related to the donor for at least ten years; must have sufficient assets and expertise to be reasonably able to enforce the terms of all easements it holds; and must have an approved policy for selecting, reviewing, and approving conservations [sic] easements that fulfill a conservation purpose. An organization that accepts contributions that it knows (or should know) are substantially overvalued or do not further an appropriate conservation purpose would jeopardize their status as a "qualified organization."
Second, the proposal would modify the definition of eligible "conservation purposes" for which deductible contributions may be made, requiring that all contributed easements further a clearly delineated Federal conservation policy (or an authorized State or tribal government policy) and yield significant public benefit.
Third, in order to take a deduction, a donor must provide a detailed description of the conservation purpose or purposes furthered by the contribution, including a description of the significant public benefits it will yield, and the donee organization must attest that the conservation purpose, public benefits, and fair market value of the easement reported to the IRS are accurate. Penalties would apply on [sic] organizations and organization managers that attest to values that they know (or should know) are substantially overstated or that receive contributions that do not serve an eligible conservation purpose.
Finally, the proposal would require additional reporting of information about contributed conservation easements and their fair market values. Section 6033 would be amended to require electronic reporting and public disclosure by donee organizations regarding deductible contributions of easements that is sufficient for transparency and accountability including: detailed descriptions of the subject property and the restrictions imposed on the property, the conservation purposes served by the easement, and any rights retained by the donor or related persons; the fair market value of both the easement and the full fee interest in the property at the time of the contribution; and a description of any easement modifications or actions taken to enforce the easement that were taken during the taxable year. As is the case under current law, personally identifying information regarding the donor would not be subject to public disclosure.
* * *
The proposal would amend the charitable contribution deduction provision to prohibit a deduction for any contribution of a partial interest in property that is, or is intended to be, used as a golf course.
* * *
The proposal would disallow a deduction for any value of an historic preservation easement associated with forgone upward development above an historic building. It would also require contributions of conservation easements for all historic buildings, including those listed in the National Register, to comply with a 2006 amendment that requires contributions of historic preservation easements on buildings in registered historic districts to comply with special rules relating to the preservation of the entire exterior of the building and the documentation of the easement contribution. Treasury Explanations, 190-192.
Reform Private Foundation Excise Tax on Net Investment Income
As discussed in Treasury Explanations, under Code section 4940, tax-exempt private foundations generally are subject to a two percent excise tax on their net investment income. However, the applicable rate is generally one percent in any year in which the foundation's qualifying distributions exceed the average level of its qualifying distributions over the five preceding taxable years. Treasury Explanations, 267. The administration proposes to "replace the two rates of tax on private foundations that are exempt from Federal income tax with a single tax rate of 1.35 percent." Id. No special reduction in excise tax would apply to tax-exempt private foundations that maintain their historic levels of charitable distributions. See id. Further, "[t]he tax on private foundations not exempt from Federal income tax would be equal to the excess (if any) of the sum of the 1.35-percent excise tax on net investment income and the amount of the unrelated business income tax that would have been imposed if the foundation were tax exempt, over the income tax imposed on the foundation." Id.
February 3, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Monday, February 2, 2015
IRS Warns Taxpayers of Fraudulent "Charities"
The Internal Revenue Service recently issued a public warning about groups "masquerading as a charitable organization" to lure unsuspecting donors, a scam making the IRS's 2015 "Dirty Dozen" list. Here are some of the highlights of the IRS's admonition:
Be wary of charities with names that are similar to familiar or nationally known organizations. Some phony charities use names or websites that sound or look like those of respected, legitimate organizations. IRS.gov has a search feature, Exempt Organizations Select Check, which allows people to find legitimate, qualified charities to which donations may be tax-deductible.
Don't give out personal financial information, such as Social Security numbers or passwords to anyone who solicits a contribution from you. Scam artists may use this information to steal your identity and money. People use credit card numbers to make legitimate donations but please be very careful when you are speaking with someone who called you.
Don't give or send cash. For security and tax record purposes, contribute by check or credit card or another way that provides documentation of the gift.
Call the IRS toll-free disaster assistance telephone number (1-866-562-5227) if you are a disaster victim with specific questions about tax relief or disaster related tax issues.
February 2, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Budget Cuts May Impact EO Rulings
According to Tax Notes Today (subscription required), at the Exempt Organizations session of the American Bar Association Section of Taxation meeting in Houston, Victoria Judson, IRS Associate Chief Counsel (Tax Exempt & Government Entities), stated that cuts to the agency's budget – 5% this year alone – could adversely affect the issuance of private letter rulings on topics important to tax-exempt organizations. The IRS may attempt to fill the void through small guidance projects addressing issues commonly appearing in requests for letter rulings, and through model letter rulings issued under an automatic approval process if a letter ruling request follows a pattern.
Electronic Cite: 2015 TNT 21-21
February 2, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Thursday, January 22, 2015
IRS Chief Counsel Formally Takes Responsibility for Most EO Rulings
Completing a previously announced realignment, the IRS formally reassigned responsibility for most rulings relating to tax-exempt organizations to the Office of Associate Chief Counsel (Tax Exempt and Government Entities) ("TEGE Counsel") as of January 2, 2015. In Announcement 2014-34, the IRS shifted responsibility away from the Tax Exempt and Government Entities Division of the IRS ("TE/GE") for revenue rulings, revenue procedures, technical advice, and letter rulings relating to exempt organizations (other than certain letter rulings relating to employee plans that will remain with TE/GE). With respect to exempt organizations, TE/GE will only retain responsibility for determination letters, including exemption determination letters and determination letters issued in response to an IRS Form 8940 (Request for Miscellaneous Determination).
Lloyd Mayer
January 22, 2015 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Wednesday, January 21, 2015
Will the Legacy of the 501(c)(4) Mess Be a Better IRS or Just a Smaller One?
The IRS "controversy" or "scandal" (depending on whom you are talking with) continues to generate significant ripples for the Service. Here are some of the most notable recent developments:
National Taxpayer Advocate Recommendations: In her 2014 Annual Report to Congress, Nina Olson called on Congress ot create an optional "safe harbor" election for section 501(c)(4) organizations that would give such organizations a numerical test they could use to ensure that their level of political campaign activity is permissible given their tax-exempt status (similar to the existing section 501(h) election for section 501(c)(3) organizations with respect to lobbying) (Legislative Recommendation #5). Ms. Olson also recomended that Congress give groups seeking section 501(c)(4), (c)(5), or (c)(6) status the ability to seek a declaratory judgement in the same manner as groups seeking section 501(c)(3) status now enjoy, and that the IRS adopt administrative review procedures for groups that have had their tax-exempt status automatically revoked (Legislative Recommendation #12).
IRS Modification of Section 501(c)(4) Expedited Application Process: In a memo released just before Christmas, the Acting Director, EO, Rulings and Agreements provided revised and clarified previously issued procedures for applicants seeking recognition under section 501(c)(4) that are given the option of choosing an expedited application process. The new procedures only apply to applicants that are given this option after the issue date (12/23/14) for the memo. Applicants who were told they were eligible for this option before that date are subject to slightly different procedures (included as Appendix B to the memo).
Omnibus Spending Bill Again Limits (?) IRS: As was the case a year ago in Public Law 113-76 (see "Cryptic Legislation" section of this post), Congress has once again included with the funding of the IRS the following limitations (Hat Tip: EO Journal):
SEC. 107. None of the funds made available under this Act may be used by the Internal Revenue Service to target citizens of the United States for exercising any right guaranteed under the First Amendment to the Constitution of the United States.
SEC. 108. None of the funds made available in this Act may be used by the Internal Revenue Service to target groups for regulatory scrutiny based on their ideological beliefs.
It is still unclear what exactly the effect, if any, of these provisions actually is.
House Oversight & Government Reform Committee Staff Report: Released by outgoing Chairman Darrell Issa, the report, not surprisingly, slams the IRS and the Obama Administration, and also promises more fact-finding.
The Shrinking IRS: As numerous news outlets have reported, the IRS faces a shrinking budget - likely at least in part because of the 501(c)(4) mess - even as the demand for its services from taxpayers continues to increase. According to Taxpayer Advocate Nin Olson, the decline is 17.5 percent since 2010, taking inflation into account (see NPR). IRS Commissioner John Koskinen has even said the agency might have to shut down for two days, with employees put on unpaid furlough (see The Hill). For other examples of the flood of coverage, see Forbes, NBC News, the NY Times, and the Washington Post.
It is too soon to make a final call, but at least some positive changes may result - clarification of the standards for political activity by noncharitable 501(c) organizations and clearance of the exemption application backlog come to mind. At the same time, the damage to the Service and the tax system seems greater - trading speed for accuracy in the application process, damaged morale among the remaining IRS employees and greater difficulty in recruiting future such employees, and a collapsing budget even as the tax law continues to become more complex.
Lloyd Mayer
January 21, 2015 in Federal – Executive, In the News | Permalink | Comments (0) | TrackBack (0)
Monday, January 12, 2015
More on the New Nonprofit Hospital Final Regs
As reported here on your faithful Nonprofit Law Prof Blog by Roger Colinvaux, the IRS issued final regulations under Section 501(r) on the requirements for nonprofit hospitals at the very end of last year.
Over the weekend, The New York Times did a report on these regulations, focusing on efforts to stop "aggressive tactics to collect payments from low-income patients." To me, the most interesting part of the article isn't the summary of the regs with regard to collections - it's the quote (and accompanying picture) from Senator Grassley: "Nonprofit hospitals and for-profit hospitals have often been indistinguishable... The rules make clear that tax-exempt hospitals have to earn their tax exemption."
It seems to me that Senator Grassley has been some what low key on charitable issues in the past few years - I'm guessing we will be hearing more from him with the resurgence of Republicans in Congress.
For other coverage of the final regulations:
- The Chronicle of Philanthropy
-briefly, at Independent Sector
I'm happy to add any other links that people have found useful.
January 12, 2015 in Current Affairs, Federal – Executive, In the News | Permalink | Comments (0) | TrackBack (0)
Saturday, November 29, 2014
Update on Nonprofits & Politics: Aprill and Colinvaux Articles, AALS Program, IRS Controversy Developments & More
While perhaps the congressional attention to the now 18 months old and counting IRS controversy will decline as the focus shifts to governing (we hope) and 2016 (unavoidably), the bubbling pot that is now nonprofits and politics continues to boil. Here are some of the latest developments:
Ellen Aprill (Loyola-L.A.) has posted The Latest Installment of the Section 501(c)(4) Saga: The Section 527 Obstacle to Effective Section 501(c)(4) Regulations, and Roger Colinvaux (Catholic) has posted Political Activity Limits and Tax Exemption: A Gordian's Knot, Virginia Tax Review (forthcoming). (And, as noted by Paul Caron when I presented at Loyola-L.A., I am working on a draft article currently titled Taxing Politics, which I should hopefully be able to post early in the new year.)
At the 2015 AALS Annual Meeting, the Section on Nonprofit and Philanthropy Law and the Section on Taxation are co-sponsoring IRS Oversight of Charitable and Other Exempt Organizations – Broken? Fixable? on Saturday, January 3rd, from 10:30 a.m. to 12:15 p.m. The topic grew out of the IRS controversy, although the panel's scope will be much broader. Marcus Owens (Caplin & Drysdale) will be moderating, and panelists include Ellen Aprill (Loyola-LA), Phil Hackney (LSU), Jim Fishman (Pace), Terri Helge (Texas A&M), Dan Tokaji (Ohio State), and Donald Tobin (Maryland).
In news relating directly to the IRS controversy, the staffs of the Senate Permanent Subcommittee on Investigations issued dueling reports, neither of which said much more than we have already heard (repeatedly) from both sides of the aisle. At the IRS, new TE/GE Commissioner Sunita Lough issued her annual Program Letter, emphasizing accountability and transparency as she continues to try to move the division beyond the controversy (referenced obliquely as "the challenges over the last year for the IRS and TE/GE specifically"). And to the annoyance of her critics, Lois Lerner gave an extensive interview to Politico.
And there is more:
- Pulpit Freedom Sunday 2014 launched on October 5th, to very limited media coverage, although there were a few stories right around election day about the over 1600 participating pastors and churches. See the stories in Politico, a Washington Post blog, and the Washington Times.
- On the election law/FEC side of things, there are lawsuits still pending that asset Crossroads GPS (Public Citzen v. FEC) and American Action Network and Americans for Job Security (CREW v. FEC) should have registered and reported as political commitees. (Hat tip: Paul Barton's article this past week in the BNA Daily Tax Report)
Lloyd Mayer
November 29, 2014 in Church and State, Federal – Executive, Federal – Judicial, Federal – Legislative, In the News, Publications – Articles | Permalink | Comments (0) | TrackBack (0)
Monday, November 24, 2014
Brewer on Recent PLRs regarding Reincorporation/Redomestication of 501(c)(3)s
Cass Brewer (Georgia State) provided the following analysis of two recent IRS private letter rulings that may indicate the IRS is rethinking whether a section 501(c)(3) tax-exempt nonprofit corporation that either changes its category of nonprofit corporation status in a single state or "redomesticates" by switching its state of incorporation has to reapply for recognition of its 501(c)(3) status.
Lloyd Mayer
Reconsideration of Reincorporation/Redomestication of 501(c)(3) Corporations?
Generally, if an IRC § 501(c)(3) organization changes its legal form (e.g., from a trust or unincorporated association to a nonprofit corporation), the new form of organization must reapply for tax-exempt status. See American New Covenant Church v. Commissioner, 74 T.C. 293 (1980)(unincorporated association becomes a nonprofit corporation); Rev. Rul. 77-469, 1977-2 C.B. 196 (same). Moreover, in Case 4 of Rev. Rul. 67-390, the IRS set forth its position that mere incorporation of an exempt corporation from one state to another requires a new exemption application. See Rev. Rul. 67-390, 1967-2 C.B. 179 (describing four distinct transactions—incorporation of an exempt trust, incorporation of an exempt association, reincorporation by Act of Congress, and reincorporation from one state to another—all requiring new applications for exempt status). The IRS's restrictive position with respect to mere reincorporation transactions involving exempt corporations seems especially harsh, particularly when compared to the much more liberal approach taken for nonexempt corporations. See I.R.C. § 368(a)(1)(F) (allowing reincorporation from one state to another with no significant income tax effect whatsoever).
Two recent private letter rulings, however, perhaps indicate that the IRS is reconsidering its position. Specifically, in PLR 201426028 (June 27, 2014), the IRS held that a legislatively mandated, intrastate conversion from "public nonprofit corporation" status to "nonprofit corporation" status did not require an organization to reapply for exemption. Then, in PLR 201446025 (Aug. 20, 2014), the IRS went one step further to hold that a "redomestication" of an exempt corporation from one state to another did not require a new exemption application. The "redomestication" in PLR 201446025 was effectuated by filing a "Certificate of Conversion" in the original state and filing "Articles of Domestication" in the destination state. According to the private ruling, the "redomestication" was undertaken because the corporate law of the destination state offered more flexibility.
To reach these favorable holdings, the IRS distinguished American New Covenant Church, Rev. Rul. 77-469, and Case 4 of Rev. Rul. 67-390 primarily on two grounds. First, with respect to the exempt corporations involved in the private rulings, controlling state law and governing documents clearly provided that each corporation's existence continued "uninterrupted" from its original incorporation and original exemption application. Second, each exempt corporation's activities, assets, and obligations (including liabilities to the IRS) remained the same before and after the reorganization transactions.
The IRS further reasoned that the state to state "reincorporation" transaction described in Case 4 of Rev. Rul. 67-390 (which required a new exemption application) was fundamentally different from the state to state "redomestication" in PLR 201446025 (which did not require a new exemption application). Without providing details, the IRS stated that the "reincorporation" in Case 4 of Rev. Rul. 67-390 resulted in a new legal entity whereas the "redomestication" in PLR 201446025 did not. Yet, in the author's experience with nonexempt corporations, reincorporations and redomestications are effectively identical (i.e., despite changing the state of incorporation the corporation's existence continues uninterrupted and the corporation's activities, assets, and obligations remain the same).
If in fact the IRS is reconsidering its position with respect to reorganization transactions involving exempt corporations, a published ruling clarifying Rev. Rul. 67-390 is critical. Otherwise, exempt corporations will be left wondering whether their reorganization transaction is a "reincorporation" demanding a new exemption application or a "redomestication" not requiring a new exemption application. In this regard it is worth noting that some states have fairly sophisticated "redomestication" statutes for nonprofit organizations (e.g., Indiana, Ind. Code Ann. §§ 23-17-31-1 through -6). Other states (e.g., Georgia, O.C.G.A. 14-3-101 through 1703) do not have such statues, relying instead on merger statutes to accomplish reorganization transactions across states. PLR 201446025 does not identify the states involved in the "redomestication" that was the subject of the private ruling. If, though, redomestication statutes are the key to avoiding a new exemption application after reorganizing an exempt corporation, this would be vitally important for tax advisors to know.
Cass Brewer
Assistant Professor
Georgia State University College of Law
November 24, 2014 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Friday, November 21, 2014
IRS Issues Favorable PLR on Change of Charity's Domicile
In Private Letter Ruling 201446025 (Aug. 20, 2014), the Internal Revenue Service ("IRS") ruled that a charitable nonprofit would maintain its tax-exempt status after changing it state of domicile by filing Articles of Domestication in the new state. The organization, originally incorporated under the laws of State 1, received a favorable determination of its exemption under Internal Revenue Code section 501(c)(3). It planned thereafter to file "Articles of Domestication" with State 2 and a Certificate of Conversion in State 1 in order to change its state of domicile. The organization sought assurance that it would continue to be recognized as tax-exempt without filing a new Form 1023 with the IRS.
According to the IRS, the conversion would not constitute "the creation of a new organization for purposes of I.R.C. § 508(a) and Treas. Reg. § 1.508-1 (a)." The IRS further concluded that the change of domicile "will not be considered a substantial change in [the entity's] character, purposes, or methods of operation under Treas. Reg. § 1.501 (a)-(1)(a)(2) for purposes of reliance on [the organization's] prior determination of exempt status." Consequently, after the change in its state of domicile, the organization may "rely on the determination of tax exempt status" previously issued to it. However, amendments to the organization's governing documents related to the change of domicile "should be reported on Form 990 as significant changes," the IRS concluded.
The IRS also stated that its analysis "would be different if a new corporation were created in State 2" and the two entities were merged, or the old corporation transferred assets to the new corporation.
Tax Notes Today (see 2014 TNT 224-4) reports that practicing attorneys are viewing the ruling favorably.
November 21, 2014 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Thursday, October 2, 2014
Leff: Preventing Private Inurement in Tranched Social Enterprises
h/t to our friends over at TaxProf Blog:
Benjamin M. Leff (American), Preventing Private Inurement in Tranched Social Enterprises, 41 Seton Hall L. Rev. ___ (2015):
Social Enterprises are organizations that are operated for the dual purpose of engaging in profit-making activity and furthering a social good. Because of their "hybrid" nature, social enterprises are perceived to be stymied by a legal system that is overly devoted to defining organizations as either businesses or nonprofits. Legal academics and legislatures have been hard at work trying to make room for social enterprises by experimenting with modifications the laws that constrain both businesses and nonprofits. One significant sector of this reform movement is devoted to making it easier for social enterprises to receive funding from both for-profit investors and charitable non-profits. They argue that social enterprises will not flourish until charitable non-profits are permitted make below-market investments in social enterprises for the purpose of subsidizing the return expected by for-profit investors. This combination of below-market charitable investments and market-rate for-profit investments is generally called a "tranched investment structure." It is not impossible under current law, but reformers argue that it is unnecessarily difficult, primarily because of federal laws restricting nonprofit activities.
This article addresses the specific legal issues raised by a tranched investment structure. Previous scholarship (and legislative reform) has focused on specific rules that apply only to "private foundations," a subcategory of § 501(c)(3) organizations, the general federal classification of charities. But, surprisingly, commentators have largely ignored the laws that apply to tranched investment structures involving any § 501(c)(3) organization. This article fills that gap.
This article argues that the IRS should issue guidance clarifying that the "private inurement regime" prevents a charity's insiders from investing in a for-profit social enterprise in which the charity is also an investor. At the same time, it should issue guidance clarifying that a fully independent charity investing in a for-profit social enterprise is not at risk of losing its tax exemption because of the "private benefit regime." Emphasizing the importance of independence as a check on abuses of the tranched structure will enable social entrepreneurs to innovate while the law continues to protect the interests of charitable contributors, the federal government and the charitable sector.
October 2, 2014 in Federal – Executive, Paper Presentations and Seminars, Publications – Articles | Permalink | Comments (0) | TrackBack (0)
Monday, September 29, 2014
What happens if charity care becomes obsolete?
An article last week in the Washington Post (h/t Chronicle of Philanthropy) discussed a report by the Department of Health and Human Services that indicated that hospitals are experiencing significant declines in charity care and bad debt, thanks to expansions in Medicaid and a drop in the number of otherwise uninsured individuals due to the Affordable Care Act. The report projects $5.7 billion (that's billion, with a "b") in savings in uncompensated care costs in 2014.
The first thing that I thought was, "Wow, that's a big number! Great news!" The second thing I thought was, "Gee, I wonder if that will change how we evaluate nonprofit hospitals." What that might say about my mental state aside, it will be interesting to see how this structural change to the way we pay for health care works its way through the standards for tax exemption.
I note that the HHS report tracks "uncompensated care," which it treats as the sum of bad debt and charity care. While the HHS report does indicate that there is a difference between "self-pay" patients and "charity care", the report is quick to note that not all hospitals break down their reporting this way. (See HHS Report, FN 6). Of course, part of the raging debate is whether bad debt is charity care – the Catholic Hospital Association says it isn't but not all hospitals agree.
Either way, under traditional formulations of the community benefit standard, charity care is not the be-all and end-all of for exempt status – it might not even be necessary. The recent trend, first evident in the Revised 990 Form's Schedule H and then in the community assessment report requirements of the ACA, appears to lean toward wanting more discussion and disclosure of charity care as component of tax-exemption, even if that doesn't appear anywhere formally quite yet. It will be interesting to see if a structural reduction in the need for charity care (however defined) changes that conversation.
Then, of course, there are the states. Having practiced in Illinois at the time of the Provena decision (good summary here), I'm particularly curious to see how that might play out. For those of you who weren't following Provena, Illinois revoked the property tax exemption for a number of nonprofit hospitals, stating that the Illinois property tax charitable exemption provisions (some of which are in the state constitution) require actual charitable use (as in relieving- poverty-charitable-use) of the property. While denying that charitable use is a numbers game (that is, you need to show that there are enough charitable dollars spent to offset the property tax uncollected) – the court then engages in exactly that mathematical exercise.
I've moved from Illinois since Provena came down, but I understand there was a legislative fix (SB 2194 and SB 3261, passed in 2012), that partially codifies this math-based analysis. What happens if a hospital doesn't meet its charity care dollars spent requirement because they are simply not necessary anymore due to ACA?
I might be going out on a limb here, but I'm guessing that Prof. Colombo might have a thought or two on this…
September 29, 2014 in Current Affairs, Federal – Executive, State – Legislative, Studies and Reports | Permalink | Comments (1) | TrackBack (0)
Wednesday, September 3, 2014
IRS 501(c)(4) Application Controversy Update
The slow motion train wreck of the IRS 501(c)(4) exemption applications controversy continues to unfold, with of course partisan spin.
Over the summer those who believe the controversy is overblown - or even that the IRS did not do anything wrong in the first place - could point to a report from the Center for Public Integrity that the IRS had denied the exemption application of the left-leaning Arkansans for Common Sense as evidence that the IRS was, or least now is, even-handed in its treatment of such applications.
Critics of the IRS could point to a report from Judicial Watch that Justice Department attorneys have admited the emails of Lois Lerner and other IRS officials are not truly lost, but that it is simply too onerous to retrieve them from an apparently cumbersome backup system. (Additional coverage: The Hill; The Washington Free Beacon). They also could point to the decision by federal District Court Chief Judge Susan J. Dlott to let some of the claims made by NorCal Tea Party Patriots against the IRS proceed, although a careful reading of Judge Dlott's opinion reveals that some of the asserted claims did not in fact survive motions to dismiss. More specifcally, the claim of vionlations of the First and Fifth Amendments and of section 6103 (relating to confidentiality of tax return information) survived the motions to dismiss as against Treasury, the IRS, and IRS employees in their official capacities, but the constitutional claims did not survive as against IRS employees in their individual capacities (the 6103 claim was not asserted against the employees in their individual capacities). Interestingly, in allowing the constitutional claims to proceed the court relied significantly on an earlier opinion in the pending Z Street case.
Lloyd Mayer
September 3, 2014 in Federal – Executive, In the News | Permalink | Comments (0) | TrackBack (0)
Wednesday, August 27, 2014
2014-15 EO Guidance Plan Includes Proposed Regs under 501(c) on Political Campaign Intervention
Yesterday the Department of the Treasury and the IRS issued the 2014-2015 Priority Guidance Plan. Included in the Exempt Organizations section of the list are numerous continuing projects, but also several new entries. The most notable new entry is "Proposed Regulations under 501(c) relating to political campaign intervention.", indicating that Treasury and the IRS plan to look at the political campaign intervention more broadly that just with respect to 501(c)(4) social welfare organizations.
Here is the full list:
1. Revenue Procedures updating grantor and contributor reliance criteria under §§170 and 509.
2. Revenue Procedure to update Revenue Procedure 2011-33 for EO Select Check.
3. Regulations under §§501(a), 501(c)(3), and 508 to allow the Commissioner to adopt a streamlined application process that eligible organizations may use to apply for recognition of tax-exempt status under §501(c)(3).
• PUBLISHED 07/02/14 in FR as TD 9674 (FINAL and TEMP) and REG-110948-14 (NPRM).
4. Revenue procedure setting forth procedures for issuing determination letters on exempt status under §501(c)(3) to eligible organizations that submit Form 1023-EZ.
• PUBLISHED 07/21/14 in IRB 2014-30 as REV. PROC. 2014-40 (RELEASED 07/01/2014).
5. Proposed regulations under §501(c) relating to political campaign intervention.
6. Final regulations on application for recognition of tax exemption as a qualified nonprofit health insurer under §501(c)(29) as added by §1322 of the ACA. Temporary and proposed regulations were published on February 7, 2012.
7. Final regulations under §§501(r) and 6033 on additional requirements for charitable hospitals as added by §9007 of the ACA. Proposed regulations were published on June 26, 2012 and April 5, 2013.
8. Additional guidance on §509(a)(3) supporting organizations.
9. Guidance under §512 regarding methods of allocating expenses relating to dual use facilities.
10. Guidance under §4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners.
11. Final regulations under §§4942 and 4945 on reliance standards for making good faith determinations. Proposed regulations were published on September 24, 2012.
12. Final regulations under §4944 on program-related investments and other related guidance. Proposed regulations were published on April 19, 2012.
13. Guidance regarding the excise taxes on donor advised funds and fund management.
14. Guidance under §6033 relating to the reporting of contributions.
15. Final regulations under §6104(c). Proposed regulations were published on March 15, 2011.
16. Final regulations under §7611 relating to church tax inquiries and examinations. Proposed regulations were published on August 5, 2009.
Lloyd Mayer
August 27, 2014 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Monday, August 25, 2014
Church Tax Inquiries Starting Up Again (without final regs)
Over the summer the Freedom from Religion Foundation announced that it had agreed to the dismissal (without prejudice) of its lawsuit against the IRS alleging that the IRS had filaed to enforce against churches the prohibition on political campaign intervention. See previous post regarding the 2013 rejection of the IRS' motion to dismiss this case for more details. What is most dramatic about this development is the letter from the IRS to the DOJ attached to the Foundation's Memorandum in Support of Motion to Dismiss detailing the current audit activity relating to churches. Here is the substance of that letter:
1. Subsequent to the publication of proposed regulations on section 7611 of the Internal Revenue Code on August 5, 2009, the IRS has processed several cases involving churches using procedures designed to ensure that the protections afforded to churches by the Church Audit Procedures Act are adhered to in all enforcement interaction between the IRS and churches. The procedures require the reasonable belief determination under section 7611(a) to be made by the Commissioner, TEGE, either directly or as concurrence to the determination made by the Director, Exempt Organizations.
2. Our written procedures for our Dual Track process for information items (a.k.a. referrals) alleging violation of the political intervention prohibition of section 501(c)(3) require evaluation of the information item by our Review of Operations ("ROD") unit and then the Political Activities Referral Committee ("PARC"). With regard to these referrals that concern violations by churches, the PARC has determined that as of June 23, 2014, 99 churches merit a high priority examination. Of these 99 churches, the number of churches alleged to have violated the prohibition during 2010 is 15, during 2011 is 18, during 2012 is 65, and during 2013 is one.
This comes after an apparent hiaitus in such activity, as detailed in a previous post. What is perhaps most surprising is that it has come without the finalization of the proposed regulations referenced in the above letter regarding exactly who, within the IRS, has sufficient authority to sign off on church tax inquiries and, if justified, church examinations.
While an intervenor represented by the Becket Fund for Religious Liberty sought to prevent the dismissal, according to the Becket Fund the court ultimately granted the requested dismissal.
Media Coverage: Christianity Today; Washington Times.
Lloyd Mayer
August 25, 2014 in Church and State, Federal – Executive, In the News | Permalink | Comments (0) | TrackBack (0)
Wednesday, August 20, 2014
Status of EO Application Backlog
Tax Notes Today (subscription required) reports that the Internal Revenue Service's Tax-Exempt and Government Entities Division is progressing significantly in clearing its backlog of exempt organization applications that existed as of the beginning of the year. TE/GE Deputy Commissioner Donna Hansberry is quoted as saying that the IRS has now closed 97 percent of the 15 percent of exempt organization applications which, at the beginning of fiscal 2014, were more than one year old.
A major reason for the backlog serves as a helpful practical reminder to exempt organizations (especially small ones) and their advisors. Hansberry attributes the increase in applications since 2010 to the rule (enacted as part of the Pension Protection Act of 2006) that automatically revokes the exemption of an organization that fails to file an information return for three consecutive years.
Electronic citation: 2014 TNT 161-5
August 20, 2014 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)
Wednesday, July 30, 2014
The National Taxpayer Advocate Isn't Happy with EO but the Form 1023 EZ Isn't the Answer
On July 16, the National Taxpayer Advocate released its mid-year report to Congress. The IRS release is here and the report itself is here.
Given all that has occurred in the last year in EO, I suppose it is not a big surpise that the Taxpayer Advocate Service (TAS) has a lot to say about EO and not very much of it is good. One of its areas of focus is the exempt status process, with the relevant part of the report entitled, "Despite Improvements, TAS Remains Concerned About IRS Treatement of Taxpayers Applying for Exempt Status."
Rather than focus on the Section 501(c)(4) and political activities issues, which makes up much of this section of the report, I wanted to focus on the TAS' comments on the new Form 1023-EZ. One would have thought that the TAS, which was been extraordinarly critical of exempt status wait times (and rightfully so), would have welcomed the Form 1023-EZ. In fact, the report notes that the TAS suggested the creation of a Form 1023-EZ as part of its 2011 report to Congress. So you'd think that the new form (available here) would be good news.
But not so much, apparently:
The National Taxpayer Advocate continues to be deeply concerned about the IRS' abdication of its responsibility to determine whether an organization is organized and operated for an exempt purpose and not mrerely accept an organization's statement to that effect.
Back in practice, the issue often arose whether to attach a certain document or not to the Form 1023. My response, with which many may disagree, was usually to attach more and not less - assuming, of course, there was really no issue to be raised by the additional documentation. I always liked the security of being able to say that we sent everything in, the IRS vetted it (or at least had the opportunity to vet it), and we could rely on having provided a complete application. Clearly, an organization submitting the 1023-EZ can't have that limited comfort, illusory as it may have been, as it really submits almost nothing as part of the application.
The TAS' primary concern appears to be with the IRS' intention to police determinations made through the 1023-EZ process with a follow-up audit. Given the state of the IRS' budget, I'm not really worried about those audits actually happening. Personally, I'm more worried for donors, who often seem to use the "Section 501(c)(3)" label as a filter for fraud protection. That probably was never truly accurate, but it's even less accurate now.
I'd love to hear thoughts....
July 30, 2014 in Federal – Executive, In the News | Permalink | Comments (1) | TrackBack (0)
Wednesday, July 16, 2014
Notes on the CPI Report on the IRS Targeting Scandal
The Center for Public Integrity has released an investigative report about the IRS Tea Party targeting scandal, in which the CPI reviewed thousands of pages of documents and interviewed dozens of insiders. The report provides a good high-level overview of the scandal, and makes a few useful findings about the Exempt Organization function within the IRS. To many, the findings may come as no surprise, but bear repeating: over time the IRS has fewer employees to regulate a rapidly growing sector, the already low rate at which the IRS investigates exempt organizations is shrinking, the social welfare category (i.e., the one at the heart of the targeting scandal) is growing, and the IRS is increasingly timid – backing down to political pressure. Unfortunately, none of this makes for an effective overseer of a vital part of civil society.
Although the report is useful, some peripheral statements should be more closely considered if only because a number of misconceptions about the IRS targeting scandal continue inadvertently to be spread. One statement in the report is that "It wasn't until the Supreme Court's Citizens United v. Federal Election Commission decision in 2010, however, that politically active nonprofits — social welfare groups as well as 501(c)(5) labor unions and 501(c)(6) trade groups — became a major force in political elections, all while receiving a de facto tax subsidy." The implication from the "de facto tax subsidy" language is that political activity, when conducted after Citizens United by a noncharitable tax-exempt like a 501(c)(4), (5), or (6), gets an unwarranted subsidy and is abusive. But this is not really right. Political activity by a noncharitable exempt generally is not tax-advantaged relative to the same activity by a political organization (aka a "527"). Rather, political activity by a noncharitable exempt actually triggers a tax that is intended to make the tax treatment of political activity consistent across sections of the tax code. There is no abusive subsidy for political activity here.
Later, the report notes that "Social welfare and other nonprofit groups galloped into the post-Citizens United era with an inherent advantage over overtly political groups: They could hide the source of their funding, regardless of whether those sources were corporations, individuals or other special interests. And they're only required tell the FEC the names of donors who give money to help produce specific ads — something that rarely happens." This point bears more than passing emphasis. The anonymity offered to donors by noncharitable exempt status, and not a tax subsidy, is the underlying legal issue at the heart of the targeting scandal post-Citizens United. In other words, the targeting scandal is not really about taxes at all, it is about donor disclosure or the lack thereof.
The report says that: "The tea party affair has directed attention away from what many IRS workers say is the much larger problem — regulating the activities of politically charged nonprofits." and also that the IRS is "supposed to ensure 501(c) nonprofit organizations don't become more political than the law allows." The broad meaning here is right: the targeting scandal has diverted attention from some real problems with the legal architecture. Also, the IRS does have a legitimate role to play when it comes to political activity and tax exemption. But these statements unintentionally play into another misconception about the IRS's role when it comes to the political activity of noncharitable exempts and political organizations. In this context, the IRS does not really "regulate" political activity in the sense of deciding whether or not the activity is permitted. Rather, the IRS's function is to classify organizations based on their purpose as measured by the quantum of their activities. This is an important distinction. The IRS does not regulate speech or activity as such; rather, the IRS, as charged by Congress, assesses organization purposes and activities and applies a tax label ((c)(4), 527, etc.). So political activity is relevant to tax classification, but it is not a question of permitting or prohibiting political activity.
The report also states that "Political '527 groups' are tax exempt like 501(c)(4) groups, but unlike them, they must disclose their donors." It should be noted that the point about disclosure is correct, but not the point about tax-exemption. Broadly, 527 groups are taxed on their investment income whereas 501(c)(4)s and other noncharitable exempts are not. So the tax treatment is not equivalent. But as noted earlier, if a noncharitable exempt engages in political activity, then a tax is triggered, which is intended to make the organizational tax treatment of political activity broadly uniform across exemption categories.
But none of this undermines the key thrust of the report's message -- that the regulatory environment of the IRS exempt organization function is in crisis and in need of constructive solutions.
Roger Colinvaux
July 16, 2014 in Current Affairs, Federal – Executive, Federal – Legislative, Studies and Reports | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 1, 2014
IRS Issues Form 1023-EZ Rules Limiting Eligibility to Smaller (Financially) Organizations
The IRS today issued rules governing use of the recently proposed Form 1023-EZ. As detailed in the instructions for this form, an organization must answer "No" to all three of the following questions relating to financial size in order to be eligible to use this shortened application form:
1. Do you project that your annual gross receipts will exceed $50,000 in any of the next 3 years?
2. Have your annual gross receipts exceeded $50,000 in any of the past 3 years?
3. Do you have total assets in excess of $250,000?
The instructions also provide 23 other questions relating to the characteristics of the applying organization (such as whether the organization is a church, school, hospital, or supporting organization), that also all have to be answered "No" for the organization to be eligible to use the Form 1023-EZ. More information about the new form is available from the IRS here, including how to obtain a copy of the form.
The IRS also issued final and temporary regulations, with the temporary regulations also serving a proposed regulations, governing which organizations are eligible to use the streamlined application process for recognition of tax-exempt status under section 501(c)(3) provided by Form 1023. Finally, the IRS issued Revenue Procedure 2014-40, which "sets forth procedures for applying for and for issuing determination letters on the exempt status under § 501(c)(3) of the Internal Revenue Code (Code) using Form 1023-EZ, Streamlined Application for Recognition of Exemption under Section 501(c)(3) of the Internal Revenue Code. This revenue procedure is generally available for certain U.S. organizations with assets of $250,000 or less and annual gross receipts of $50,000 or less."
Lloyd Mayer
July 1, 2014 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)


text:
10 units
3000 level
Course handbook
This course strengthens students' knowledge and understanding of human development and behaviour, and extends students' ability to work with people with mental illness and disorders. Studies in life-span development and contemporary theories of human biological, psychological and social development, behaviour, and adaptation, are designed to enable students to more effectively utilise evidence-based interventions such as basic cognitive behaviour therapy. Students will examine therapeutic options applicable for use by health care professionals in health care settings. These options will include a range of e-therapies available for high-prevalence disorders such as anxiety and depression. Tutorials focus on exploring therapeutic options and strengthening students' capacity for self-reflection and therapeutic engagement.
Availability2017 Course Timetables
Port Macquarie Nth Coast Inst
- Semester 2 - 2017
- Semester 2 - 2017
- Semester 2 - 2017
Learning outcomes
On successful completion of the course students will be able to:
1. Demonstrate knowledge, skills and understanding integral to Professional practice
2. Demonstrate knowledge, skills and understanding integral to critical thinking and analysis
3. Demonstrate knowledge, skills and understanding integral to Provision and coordination of care
4. Demonstrate knowledge, skills and understanding integral to collaborative and therapeutic practice
- Collaborative and therapeutic practice to ensure a person-centred focus in all interventions
- Participating in the delivery of recovery-focused interventions
- Responding effectively to clients with a range of mental disorders
- Implementing a holistic approach to person-centred care in a range of settings, including the ability to participate effectively as a member of a multi-disciplinary team
- Demonstrate effective performance in identifying potential mental health problems when conducting a client assessment
- Display an awareness of a range of psychosocial interventions
- Reflect on a growing self-awareness and personal insight
This course is only available to students active in the Bachelor of Nursing program or Bachelor of Midwifery Program and have successfully completed 2nd year requirements.
Assumed knowledge
A pass or higher grade in all 2000 level courses
Assessment items
Presentation: PowerPoint Presentation with Narration
Essay: Essay
Contact hours
Callaghan, Ourimbah and Port Macquarie Nth Coast Inst
Online Activity
Online 2 hour(s) per Week for Full Term
Self-Directed Learning
Self-Directed 4 hour(s) per Week for Full Term

subset: commoncrawl


text:
Turkis Prime Minister Gul hosted a dinner for members of the Alevi community in his nation which was probably the first time a Turkish government official had taken such a step. The Alevi are considered a liberal denomination of the Muslim faith and are subject to extreme persecution and discrimination in other Muslim nations. Many Alevi boycotted the dinner because they doubted the sincerity of the prime minister. Erdogan told the audience of Alevis, "we all belong to this country, we are all brothers. We must know and understand one anotheer. We must not give in to those who would sow division." However, even as he spoke, a Turkish court turned down a request by Alevis that their place of worship, a "cemevi" could be recognized as equivalent to a mosque.
The Alevis have long been fighting to attain equal rights in Muslim nations. The Turkish court decision is unfortunate because it fails to acknowledge the right of Muslims to have their own beliefs and accords to government the right to decide which is or is not an official house of worship. We applaud Prime Minister Erdogan for reaching out to those who are facing discrimination in his nation.


text:
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text:
Different players just keep stepping up for the Nashville Predators, and now their magical postseason run has an even bigger destination: the franchise's first trip to the Stanley Cup Final.
Colton Sissons scored his third goal with 6:00 left, and the Predators eliminated the Anaheim Ducks with a 6-3 win in Game 6 on Monday night in the Western Conference finals.
"In the back of your head, you've been thinking about the Finals and then when the buzzer goes off, it's an amazing feeling," Nashville goalie Pekka Rinne said.
The Predators, who've never won even a division title in their 19-year history, came in with the fewest points of any team in these...


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Calcutta: An emotional Ricky Ponting on Thursday lost his customary composure when he told his teammates that he would bring the curtains down on an illustrious 17-year career after the third Test against South Africa beginning in Perth, on Friday.
At a press conference, the 37-year-old said that he was calling it quits as he has not been performing to the desired level.
The effect of Ponting's retirement was writ large across the red eyes of the captain, Michael Clarke.
"I didn't have a feeling it was coming," Clarke said. "Ricky spoke to me after the Adelaide Test match and made his decision I guess over the last few days. The boys are obviously upset at the moment. He's been an amazing player for a long time… That'll do me for today. Sorry, I can't answer that."
The following are excerpts from Ponting's address to the media and the press conference
As you probably seem like you're all very aware now, a few hours ago I let the team know of my decision to make this Test match my last. It's a decision I thought long and hard about, put in long consideration about the decision… At the end of the day it was based on my results and my output really in this series so far. It hasn't been what I expect of myself and it certainly hadn't been to the level that I feel is required for batsmen and players in the Australian team.
As I've said all along, I'll continue to play this game as long as I feel I could contribute to wins, play well enough to help the team win, and over the last couple of weeks I think that my level of performance hasn't been good enough to do that.
My passion and love for the game hasn't changed one bit, right through the last 12-18 months when things probably haven't been as I would've liked them or pictured them. I'll continue this season to play out the rest of the summer, and I'm looking forward to a full season of the Big Bash with the Hobart Hurricanes.
But I think it's really important today, I could sit here all day and reflect on my career and talk about the great teams I've played in, the great players I've played with and against, but I honestly believe that's for another time, there's other days and times for that at the end of this game… At the end of my career we can all get together and talk about those moments.
As far as I'm concerned, my immediate focus now and the team's immediate focus is what we're presented with tomorrow. That's an unbelievable opportunity. We're going into what I believe is almost like a grand final. I've prepared well this week, and as I said to the boys this morning, I'm hungrier than ever and want this win probably more than any other game I've ever played in, so I'll do whatever I can this week to contribute to a great team performance.
If that happens to lead to a win for the team and we get back to the top of the tree and No. 1 in the world then there's no better time for me to finish anyway. This week we've got a big job ahead, and especially me, I've got to lift my level of play from where it was last week to where it is this week. I've got a good feeling I can do that, and as I said there's no better stage than in a finals type game, a big game, to try to do that this week. Ironically, this is where it all started for me, I think 17 years ago, this is where it all started, and that's where it's going to finish.
On how hard it was to discuss retirement
The lady sitting beside you there (wife Rianna) was the first one I spoke to about it. It was towards the end of the Adelaide game when I first started contemplating what it might mean, and contemplating if I believed within myself if I was good enough to play the way I've been known to play through the years. I think the thing that struck home mostly was that only a few weeks ago I felt my preparation had been as good as it has been for a while. My Shield form had been good, I'd scored runs, I felt good about my batting, but when the big moments come around I haven't been able to delivery what's been required for the team. That was when I first started thinking about things. We spoke long and hard and there's been a few sleepless nights over the last couple of days to reach the decisions, but I'm very comfortable with the decision I've made. I think timing wise it's the right time. At the end of the series it'll give whoever my replacement is the chance to start afresh in a new series and for me those little things have been pretty important as well.
His contribution to the game
I know I've given cricket my all. It's been life for 20 years. Not much more I can give.
If there was one moment or dismissal that triggered this
I want to be a consistent performer, and if you look back over the last 12 or 18 months I haven't been able to perform consistently. I've had moments of really good stuff, and prolonged moments of cricket that's been below my expectations and below a par level for me, so there hasn't been one dismissal or one moment, it's just been in my own eyes reasonably consistent failure. That's why I believe the time is right now to be making this decision.
Whether he had the unanimous support of the selectors
I believe so, there's been all sorts of things in the papers the last couple of days and I know certainly with my captain and my coach I couldn't have had any more support from those guys, and they've been the ones who've been most verbal about their support. This is not a decision that's been made by the selectors, this is a decision that's been made by me, and I'd like to thank all those guys for the support they've given me over the last 12 months. There were probably moments when they thought long and hard about ending my career and I'm glad I've got the opportunity to finish this way and on my terms.
Missing the Ashes next year
It's not tough at all, because I've made up my own mind that I'm not good enough to get there. So that's not a tough decision. When you've come to the realisation that what you can give is probably not good enough then it's a pretty easy decision.
His plans after cricket
I've got a few months of cricket yet, which I am really looking forward to. I really enjoyed the start of this season playing cricket with Tasmania and back with some of my mates… So I'll enjoy that for what it is, but this is my new team here (pointing to his family).
His teammates' reaction
I tried to tell them a lot, but I didn't get much out. As I said to the boys this morning, they've never seen me emotional, but I was this morning…
Thoughts on who should replace him in the team going forward
Thankfully for me I've never been a selector, right through my time, and probably right at the moment I'm thankful I'm not a selector again. But I guess it's really pleasing from my point of view that there are a few guys out there in Shield cricket who are scoring runs at the moment. I know whichever way the selectors decide to go with the next player, they'll play well for Australia. We've got great structures, great set-ups now around our team, the next player will be given every opportunity and I'm sure they'll do well.


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Nice quality
Comments about ToughOne Plate and Fin Evaporator Core:
On a GMC you have to remove the dash to install one of these. After removing the dash and installing we found it leaking, not at a fitting, but in the tubing itself. Had to remove the dash a second time to remove it and install another one. Do yourself a favor and leak check before installation. Second new one works fine.
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Appears to be as good as OEM
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cheap part expensive install
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text:
Like the way cops start to know you is say you hit up a zoo (hey come on, banksy did it!) the owner would tell the police and the police would keep a record, blah blah blah your record gets big and they decide they want to get you.
But i don't get what they do from there? Watch CCTV camera's and follow you home? i think someone would have to rat on you. Or they come onto bombing science and get your IP and get your address that way :P
Have you guys seen the movie Jisoe?
Its on youtube just type in jisoe
He shows you his album it looked like he had about 25 to 40 trains in his album? So i think its when you "hit it big" and start doing serious shit like trains that they start to care?
Is anyone else sick of all the people that brag about doing graff? like people who have myspace and shit and show themselfs doing it all?
And like you will meet this guy and he goes "my name is Joe i do graffiti"


text:
Dancers use their bodies to tell a story, much like charades players try to get their teams to guess "every event in the Mahabharata." Marvel at a speechless tale with this GrouponLive deal to see Moments of Sentiment performed by Rodriguez Dance Theatre. For $12, you get general admission for one on Saturday, January 26, at 7:30 p.m. (up to a $25 value). Doors open at 6 p.m. for a reception and an art exhibition.
Founded by Lisette Rodriguez in 2007 following her graduation from the University of Wisconsin–Milwaukee with an MFA in dance, Rodriguez Dance Theatre gives local artists the chance to hone their skills with a professional troupe. Before the show, viewers can prime their creative appreciations with an art exhibition and a reception.
Rodriguez Dance Theatre 2011 Trailer
View a montage of performances to see the troupe's dancers in action<p>
2121 S Goebbert Rd.
Arlington Heights, IL 60005
+18474770883Get Directions


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- Style LK131497/Sku 407269
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- Model Info: Height: 6' 1" | Chest: 40" | Waist: 31" | Hip: 39 1/2" | Wearing Size: Large
- 60% Cotton, 40% Polyester.
- Turn inside out and machine wash cold with like colors. Tumble dry low.
- Imported
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"Clickprint fellows were amazing doing my signage job. My signage was fantastic and looked great with special effects you were professional and on time. Prompt communication throu.."Blacktown, Sydney
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text: REDMOND, Wash., Jan. 17, 2013 /PRNewswire/ -- With every search that people do, Bing believes there is a person out there who can help you make a decision. This is why Bing lets you tap into the wisdom of friends and experts in the social sidebar. Starting today, you will see an average of five times more Facebook content in the sidebar, including status updates, shared links, comments and photos from your friends. Bing is the only search engine where you can find relevant search results along with the people who can help you make a decision – so you can spend more time doing and less time searching. To view the multimedia assets associated with this release, please click: http://www.multivu.com/mnr/59880-bing-brings-more-of-facebook-to-search (Photo: http://photos.prnewswire.com/prnh/20130117/MM43333) Say you're thinking about making your first trip to Coachella and decide to research it online. When using Bing, you will find not only great search results about the festival, such as when it is and how to get there, but also pictures, posts, comments and more from your friends who attended the festival in the past. Now you know all there is to know about Coachella and which of your friends might have the inside scoop or, better yet, want to join you. Bing doesn't stop there. It will also show you advice from experts across Twitter, Foursquare, Quora, Klout, Google+ and more to help you make the most of your trip. Want to try it out? Getting a little help from your friends is only a step away. Visit Bing, click on Connect to Facebook, and you're good to go! As you would expect, Bing lets you control what you share and respects your Facebook privacy settings. What are you waiting for? Stop searching alone, and let Bing put your social network to work. Sign in to Facebook at http://www.Bing.com to experience the benefits of social search. About Bing Bing is the search engine from Microsoft, designed for people who do. For people like you who are always doing more and don't have time to sit still. Now, only Bing brings together the best search and the best people from your social networks, like Facebook and Twitter, to help you spend less time searching and more time doing. So whether you're on your PC or on your phone, Bing is designed not just to connect you to the information you are looking for, but also to help you get things done right on Bing.com. About Microsoft Founded in 1975, Microsoft (Nasdaq "MSFT") is the worldwide leader in software, services and solutions that help people and businesses realize their full potential.


text:
good to see people doing work, unlike me
just floting around the vortex and found this:
good to see people doing work, unlike me
just floting around the vortex and found this:
quoted by me:
"vdubs are like wifes"
"they always want money,and you never have enough for them"
"you always want to beat them,but you know it will just cost you more"
looks like jamie's old car.
most definately. i have to say i think it looked a lot better the way jamie rocked it
you guys know of anyone rolling around in a black b5 passat or mk4 jetta with wheels, exhaust, and yellow fogs? had one with NH plates pass me going north on 91 last night.
Passat sedan works at grafton county. Car is super clean, probably one of the nicest b5's I have ever seen
So the GTI is officially going back to stock. The only piece that will be left modified is the noise pipe and I don't think that is noticable enough to effect trade value. My mechanic is swapping the exhaust systems for me while I am in florida the first week in december. I just bought the pins to put my stock intake back on. If the weather is at all decent one of these days I may tackle the suspension. Be much better doing that in a garage somehwere though...
I will be driving some form of mk6 in 2011. Can't wait to see the new GLI but I also really like the shadow blue GTI's. Only thing for certain is boost and a stick. No more messin around with this DSG for me
Are you still interested in those springs?
quite possibly.
do you need anymore stock parts?
Not really, the only thing that will be left non-stock is the noise pipe but I don't think that is even worth messin with. I just have it plugged and it will be hidden by the engine cover.
yeah and that's not even a 'performance' piece as much as it is cosmetic.
I you let me use your garage and give me a hand I'll give ya those springs for $50 bucks. The way I see it is that I plan on raising it up to trade in the spring so I might as well raise is up now so I don't have to avoid everything in the road this winter.
sounds like a plan to me
rich, whenever you want to use the garage is good. sundays are best, but i'm sure we can work out a time. i'm still not sure about the springs. still debating coils. i'll def give you a hand with your suspension though either way.
Its no huge rush cuz your car is parked for the winter and I am not trading till spring. I am out of town all next week. Headed to Disney in FL. I'll catch up with ya when i get back.
hello gents, long time no tex... suby is officially in winter mode.. now for the dub to get some love..i know i've been dragging my heels but cody twisted my arm abit and we found some wheels that will be orderd before 2011..
also looking for a different set of coils.. i bought some cheap new fk's over the summer, but those will
go in my girls 1.8t beetle..
whoops sorry about the size
really missed having those gtg's this year. Those were the days man...
Hope to have some new wheels this summer and a renewed vigor for the car stuff
Going to meet mickey and minnie mouse tomorrow. I feel like a little kid cuz Im pretty excited lol
maybe he will have liked it enough to come over to vw lol.
Everyone should be jealous, I just want outside to watch the dolphins swim by in shorts and a t-shirt. Enjoy new england this week everybody
im jealous too. i get to sit in a class all week in lewiston me. no windows. drive there in the dark and drive home in the dark.
hope you guys have a great time
quoted by me:
"vdubs are like wifes"
"they always want money,and you never have enough for them"
"you always want to beat them,but you know it will just cost you more"
Last night it was 32 degrees here in sunny Florida. Felt right at home for us new englanders Supposed to warm up later in the week though by the time we go to Disney.
there's an '88 audi quattro coupe for sale in bradford. not sure of the price, but looks to be in okay shape. sign says it runs good, but needs a fuel line. anyone have any experience on difficulty or price on fixing said fuel line?


text:
New Buffalo, MI, USA < change city >
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Hotels/Accommodations, Rest...
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ABSOLUTELY AMAZING...ALL THE WABSOLUTELY AMAZING...ALL THE WAY AROUNDAY The food ...
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For the best food and service you can't go wrong with Great Lakes. Ed Kis thinks ...
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Stevensville, MI, United States
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Food is extremely good. They will seem a bit overpriced at the beginning, but on...
157 Bistro
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Valparaiso, IN, United States
1 rating, 1 review, 1 wedding
Everyone raved about the food and were very professional throughout the wedding r...
Chris Ferris Catering
Benton Harbor, MI, USA
1 rating, 1 review, 1 wedding
We love Chris! She did a fabulous job working with us on our vision, our values, ...
Valparaiso, IN, United States
1 rating, 1 review, 1 wedding
Pesto's!! I Highly recommend. I live in Amherst NY and had the pleasure of workin...


text:
mower won't start
New Toro (with Kohler motor) mower last year.
Last week I pulled the rubber cap off spark plug while I tipped it and cleaned 2" of built up grass packed underneath.
Today tried to start it and it wouldn't even catch. Remembered the black rubber cap and put it back on the spark plug. Tapped it lightly with hammer to make sure it was snug.
Still won't start. I replaced the air filter 2 weeks ago.
It's a PIA to borrow my daughters suv and wait for her to help me lift it to take it to a repair shop.
any suggestions? Thanks.
Remove spark plug
Pull rope to purge cylinder
Re-connect rubber cap to spark plug
Set controls as for starting
Hold threaded portion of plug to cyl. head, pull rope to check for spark
If spark plug has spark, :thumbup: I'm making progress
Replace spark plug and rubber cap
Remove air filter and put a table spoon ( measured ) of gas in carb.
Pull rope and start
ALSO, before reading this reply I went out to try and start it again. One thing about this Kohler it has an 'easy start'.
No luck. Nothing. I took the cover off the filter and the filter is soaking wet with gas.
And, gas is still dripping out the front, running thru the area where the air filter goes.
I've never had that happen before. My garage smells like gas so I raised the door so it airs out.
Why is gas running out?
I used the hose and tried to clean out the new filter and now am letting it dry before putting it back in.
Besides having trouble getting the mower into a shop the guy who has the only shop I know of, is a jerk.
FAirview, how do I get the spark plug out? Don't I need a special tool for that? Will I shock myself while I'm doing it?
I better get the directions back out and see what a carburetor looks like so I know where to pour the tablespoon of gas.
Please move the mower outdoors. Leaking gasoline isn't safe in a garage.
With this new information, disregard putting a tablespoon of gas into the carburetor throat opening.
Get a mower mechanic that's not a jerk to solve the unwanted gas flow problem and throw that air filter away unless it was designed to be washed.
Fairview, I need to take it in to have the blade sharpened anyway, so might as well do it now.
This mower has a "Recycler" so it doesn't leave globs of grass when you mow. Sometimes it rattles and clanks and shuts off. I think that's when the grass is too deep or wet and it clogs up underneath. That's why I tipped it over last week to clean it out.
It looks like there are 2 rubber hoses going somewhere from the gas tank. I wonder if one came loose? Is that possible? Even tho it's Florida I doubt the hose rotted in just one year.
I did put it outside.
The float is just stuck in the carburetor.
It's a simple DIY repair with a few simple hand tools.
Remove and disassemble it.
Shot some carburetor cleaner into all the ports.
And put it back together.
All the pieces are made so they can only go one way when assembling.
Why not sharpen the blade yourself and save a few bucks?
If you added an additive that counter acts the effects of ethanol fuel or use non ethanol fuel you may avoid having to go through this again.
Ethanol eats up and things made of plastic or rubber and gums up the insides of the carburetor.
To remove the spark plug, all you need is a socket and socket wrench. Generally the size is either 5/8" or 11/16". You could probably get by with a pair of channel lock pliers or a crescent wrench, though. Pull the boot off the spark plug, and loosen the plug with the wrench, and unscrew the rest of the way with your hand. You won't get shocked (as long as no one is pulling the cord while you're doing it!) Check out this video for a better understanding. It's obviously not the same mower you have, but the concept is pretty much universal.
When you tipped the mower over, did you tip it where the carb and air filter point down towards the ground? If so, it's possible that this is where your gas 'leak' came from, just excess fuel running outside of the tank or carb, and soaking into your air filter. It's a gratifying experience to be able to maintain and work on your own equipment, but it certainly has a small learning curve. I wouldn't be eager to pack up a push mower and lug it to a small engine shop without giving it my due diligence first.
NegativeTen, I did happen to see on the directions to tip it towards where the oil is............which is opposite the gas and air filter. You're right, it's very gratifying to accomplish things myself, around the house. What amazes me is that many things are simple, it's just that I didn't know how to do them. Thanks for the link. I like these howto videos but didn't think to find one.
Joe, thanks for your input. I use the same gas as for the car. The gas was trickling out pretty fast. I found a video and yes it appears that a stuck float can cause a leak.
It's still leaking and it's been over an hour. I'm soaking up the gas with rags but then don't know what to do with the rags as gas isn't good for the atmosphere.
I know how to solve this. There's a retired mechanic a few houses away and he's always wanting to do things for me, which I firmly decline. I'll call him tomorrow and take my mower up there. edit: that won't work. The neighbor has a cast on his arm.
edit: hey I didn't even know we had a 'mower' forum here. Sorry for posting in the wrong spot. How would a person find this? I looked under 'forums' for the list and 'tractors and mowers' is not listed.
2 Attachment(s)
Here are photos where I see it leaking. This rectangle area is where I took the air filter out. Also read instruction booklet again and there is no reference or info on carburetors. The neighbor isn't home. I'm going to take the top off and just look to see if I can find the float.
Attachment 75183Attachment 75184
new photos. Hunting for float.
2 Attachment(s)
got the top off and removed the piece that holds the air filter. (I hate when this happens, but a little ring fell off from somewhere, but I may figure out where it goes when I put it back together.
I don't see anything that looks like the float valve I see online. Does anyone know where it is? thank you.Attachment 75248Attachment 75249
1 Attachment(s)
This is the carb. The float valve is inside. The big bowl on the bottom comes off. Removing the bolt on the bottom should allow the bowl to drop off and give you access to the guts of the carb.
Before you take it all apart, have you tried starting it since you took off the air cleaner?
gas was steadily dripping out (after I put fuel in and tried to start it), so there's no gas in it now. The gas dripped right below the air filter.
ok, I'll keep taking the screws off but am a bit worried I won't put everything back together right or won't find a problem.
I think the float is stuck (as Joe indicated) and that's why the fuel dripped out. I don't have any way to get it to a shop soon and need to mow by Friday when I leave on vacation.
edit: rats! I see 2 screws in the bottom of the float. One is at an angle, and the other is directly on the bottom. I can't budge the bottom one and there's no space to get leverage. I give up.
BUT, on another matter, am I understanding this right............marine gas would be better for my mower? There are marines all around me here in Fla. I have a 2 gal gas can, would I use marine gas the same as car gas, meaning, don't let it sit over the winter?
thanks anyway.
Marine gas doesn't contain ethanol which is in car gas. The ethanol is bad for small engines. If you can get it, use it but don't let it sit over winter. There are also additives you can add to car gas to help counteract the affects of ethanol.
wow, just got some estimates to fix (what I assume is wrong) the carb float. Up to $100 plus standard $25 service fee. Plus the time is 2 to 4 weeks to repair. They must be busy this time of year.
Even tho my neighbor has a cast on his arm would I sound awful if I asked if he could supervise me fixing the float.
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Water is synonymous to life and the importance of drinking water cannot be emphasized enough. Water is one of the main constituents of our body and this is evident from the fact that 60% of our body is water. To keep the governing center of our body, the brain, hydrated we need to drink water because 70% of the brain is made of water. Every cell and the blood need water for maintaining the right pressure and balance inside our body. The very first living organism originated in the water of ocean. One of the most vital functions of water is to help in excretion. It removes the harmful toxins and chemicals from our body. If we drink little or no water then we will face problems in urination and fall ill.
Drinking little water makes us thirsty because the brain needs water and it sends signal telling us to drink water to meet the needs of the body. Meager consumption of water can cause cellular dehydration and disrupt the digestion procedure. Cellular dysfunction can lead to dangerous consequences including severe imbalance of the physical functions and the pH levels of our body. Water controls the body temperature by removing the excess heat through sweating and evaporation of the sweat from our body surface.
Water is needed to conduct most of the chemical reactions inside our body. Without water every chemical reaction will be incomplete. Doctors and health experts suggest that each individual drinks at least 7 to 8 glasses full of water. If you do not drink sufficient amounts of water you can become dizzy and suffer from mood swings due to dehydration. Acute and persistent lack of water can lead to coma and even death. Water is something we need in a daily basis because it goes out of our system through sweat and urination. It is necessary for our well being.
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