Tax-exempt organizations, by definition, are exempt from federal income tax under various provisions of the Internal Revenue Code. However, some are directly involved in Abusive Tax Avoidance Transactions (ATATs).   In addition, because they are tax-indifferent, tax-exempt organizations are, at times, used by for-profit entities as accommodation parties in these transactions. Identifying and responding to ATATs involving tax-exempt organizations is critical to the IRS objective of discouraging and deterring non-compliance within tax-exempt and government entities. Commissioner Everson emphasized this in a hearing conducted by the Committee on Finance, U.S. Senate on Charitable Giving Problems and Best Practices.

Listed Transactions Involving Tax-Exempt Organizations

501(c)(15) Producer Owned Reinsurance Companies (PORC)

S-Corporation Tax Shelter Strategy

Emerging Issues

Credit Counseling Organizations

Corporation Sole Organizations

501(c)(15) Overcapitalization ("Stuffing") Transactions

Other Abusive Tax Avoidance Transactions

Employee Plans

Corporations

Trusts

Report an Abusive Transaction Involving an Exempt Organization

IRS
EO Classification
MC 4910DAL
1100 Commerce Street
Dallas, TX  75242