The lobbying deduction disallowance: policy considerations, comparisons, and structuring activities under amended section 162(e)

Article Abstract:

Congress' 1993 lobbying expense deduction disallowance appears to be based on questionable social policy considerations, but IRS releases under the IRC section 162(e) disallowance provide planning opportunities for noncharitable exempt organizations engaging in lobbying activities. In addition to the deduction disallowance, Congress has imposed recordkeeping and proxy tax obligations on tax-exempts. Organizations can minimize the risk of noncompliance by using a charitable organization to engage in some lobbying activities, as well as taking advantage of available waivers, de minimis rules and distribution of costs incurred.

Lobbying

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The need for guidance on the use of physician recruitment incentives by nonprofit hospitals

Article Abstract:

The IRS needs to provide nonprofit hospitals with additional guidance on permissible physician recruiting activities to ensure that risks to tax-exempt status do not chill efforts to meet community health care needs. The IRS should not treat all physicians as insiders in determining whether offering recruitment incentives compromises hospitals' exempt purposes. Instead, the IRS should apply private benefit analysis alone to recruitment of new physicians. A combination of private benefit and private inurement analysis should be applied to retention incentives offered to physicians already at the hospital.

Hospitals, Community Hospitals, Physicians, Medical professions, Recruiting, Employee recruitment, Hospitals, Voluntary, Voluntary hospitals

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Rethinking section 162(m)'s limitation on the deduction of executive compensation: a review of the commentary

Article Abstract:

The broad exceptions provided in IRC section 162(m) and accompanying regulations undermine the policy goals of limiting the deductibility of executive compensation. One exception in particular, the qualified performance-based compensation exception, allows corporations unlimited deductions provided certain procedures are used. The policy of controlling increasing executive salaries is not served by creating procedures that can easily be overcome through careful planning.

Compensation and benefits, Executives, Executive compensation

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