Congress and the Internal Revenue Service (IRS) are concerned about
international tax havens, blocker organizations, and the operation of American
Friends organizations abroad. This area was highlighted as a focus in the IRS
work plan for 2011 released in December 2010. In its 2011 work plan, the IRS
said that international tax enforcement is a priority for it. Taxpayers with
international activities, transactions and accounts will be a primary focus.
The IRS’ concern in this area is whether charitable assets of tax-exempt
organizations are being diverted for non-charitable purposes, and it will
- Foreign entities that have received IRS recognition of tax-exempt
- Information referred from the Joint International Tax Shelter
- Charities that participate in “gifts in kind” programs where valuation
issues surface from non-cash items donations to foreign entities.
- Large private foundations with international operations.
“The Globalization of Philanthropy; International Charitable Giving in the
Twenty-First Century,” by McGuireWoods attorneys Milton Cerny and Michele A.W.
McKinnon, published in the Real Property, Trust and Estate Law Journal of the
American Bar Association, discusses
these and other issues that confront charitable organizations and individuals in
the planning and managing of their international operations.
McGuireWoods Nonprofit &
Tax-Exempt Organizations Group
nonprofit and tax-exempt services lawyers
provide advice and guidance that enable
charities and other nonprofits to operate
efficiently and effectively in today’s
increasingly complicated, regulated and
This article was highlighted in the EO Tax Journal Email Update on January 31, 2011.