Webtransactions under section 4958, because the IRS never recognized O as an organization described in section 501(c)(3), O was never an applicable tax-exempt organization under section 4958. Therefore, these transactions are not subject to the excise taxes provided in section 4958. Example 2. O is a nonprofit corporation formed under state law. WebSection 4958 (f) (1) defines disqualified person, with respect to any transaction, as any person who was in a position to exercise substantial influence over the affairs of an …

26 U.S. Code § 4958 - Taxes on excess benefit transactions

WebOct 9, 1999 · Section 4958 (f) (1) (A) uses the following definition: “any person who was, at any time during the 5-year period ending on the date of such transaction, in a position to exercise substantial influence over the affairs of the organization.” WebA foreign organization, recognized by the Internal Revenue Service or by treaty, that receives substantially all of its support (other than gross investment income) from sources outside … citas heraclito

Intermediate sanctions - Wikipedia

WebAn applicable tax-exempt organization may provide an excess benefit indirectly through the use of one or more entities it controls. For purposes of section 4958, economic benefits provided by a controlled entity will be treated as provided by the applicable tax-exempt organization. ( B) Definition of control -. (1) In general. Websection 4958(f)(4) and paragraph (b)(1) of this section. (B) Profits or beneficial interest. For purposes of section 4958(f)(3) and this paragraph (b)(2), the ownership of prof-its or … WebSection 4958 adds intermediate sanctions as an alternative to revocation of the exempt status of an organization when private persons benefit from transactions with a 501(c)(3) public charity or 501(c)(4) non-profit organization. ... On August 4, 1998, the IRS proposed regulations to implement IRC 4958. On March 16 and 17, 1999, the IRS held ... diana of triers