Internal Revenue Bulletin 2016-24

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb16-24.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

Announcement 2016–22, page 1028. Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

Finding Lists begin on page ii.

Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).

Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

June 13, 2016 Bulletin No. 2016–24

Announcement 2016–22

Deletions From Cumulative List of Organizations, Contributions to Which are Deductible Under Section 170 of the Code

Table of Contents

The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. Generally, the IRS will not disallow deductions for contributions made to a

listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, con

tributions from individuals and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on June 6, 2016 and would end on the date the court first determines the organization is not described in section 170(c)(2) as more particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation.

Effective Date of

NAME OF ORGANIZATION Revocation LOCATION

Bureau of Indigenous Muslim Affairs May 15, 2014 Elizabeth, NJ

Operation Reach, Inc. January 1, 2012 New Orleans, LA

Texas Highway Patrol Museum January 1, 2015 Austin, TX

June 13, 2016 1028 Bulletin No. 2016–24

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect:

Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).

Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.

Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A

The following abbreviations in current use and formerly used will appear in ma- terial published in the Bulletin.

A —Individual. Acq. —Acquiescence. B —Individual. BE —Beneficiary. BK —Bank. B.T.A. —Board of Tax Appeals. C —Individual. C.B. —Cumulative Bulletin. CFR —Code of Federal Regulations. CI —City. COOP —Cooperative. Ct.D. —Court Decision. CY —County. D —Decedent. DC —Dummy Corporation. DE —Donee. Del. Order —Delegation Order. DISC —Domestic International Sales Corporation. DR —Donor. E —Estate. EE —Employee. E.O. —Executive Order. ER —Employer.

and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.

Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.

Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the sub

ERISA —Employee Retirement Income Security Act. EX —Executor. F —Fiduciary. FC —Foreign Country. FICA —Federal Insurance Contributions Act. FISC —Foreign International Sales Company. FPH —Foreign Personal Holding Company. F.R. —Federal Register. FUTA —Federal Unemployment Tax Act. FX —Foreign corporation. G.C.M. —Chief Counsel’s Memorandum. GE —Grantee. GP —General Partner. GR —Grantor. IC —Insurance Company. I.R.B. —Internal Revenue Bulletin. LE —Lessee. LP —Limited Partner. LR —Lessor. M —Minor. Nonacq. —Nonacquiescence. O —Organization. P —Parent Corporation. PHC —Personal Holding Company. PO —Possession of the U.S. PR —Partner. PRS —Partnership.

stance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded.

Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

PTE —Prohibited Transaction Exemption. Pub. L. —Public Law. REIT —Real Estate Investment Trust. Rev. Proc. —Revenue Procedure. Rev. Rul. —Revenue Ruling. S —Subsidiary. S.P.R. —Statement of Procedural Rules. Stat. —Statutes at Large. T —Target Corporation. T.C. —Tax Court. T.D. —Treasury Decision. TFE —Transferee. TFR —Transferor. T.I.R. —Technical Information Release. TP —Taxpayer. TR —Trust. TT —Trustee. U.S.C. —United States Code. X —Corporation. Y —Corporation. Z —Corporation.

Bulletin No. 2016–24 i June 13, 2016

Numerical Finding List ¹

Bulletins 2016–1 through 2016–24

Announcements:

2016-1, 2016-3 I.R.B. 283 2016-2, 2016-3 I.R.B. 283 2016-3, 2016-4 I.R.B. 294 2016-4, 2016-6 I.R.B. 313 2016-5, 2016-8 I.R.B. 356 2016-6, 2016-10 I.R.B. 409 2016-7, 2016-8 I.R.B. 356 2016-8, 2016-9 I.R.B. 367 2016-9, 2016-9 I.R.B. 367 2016-10, 2016-9 I.R.B. 367 2016-11, 2016-10 I.R.B. 411 2016-12, 2016-16 I.R.B. 589 2016-13, 2016-13 I.R.B. 514 2016-14, 2016-14 I.R.B. 535 2016-15, 2016-17 I.R.B. 636 2016-16, 2016-18 I.R.B. 697 2016-17, 2016-20 I.R.B. 854 2016-18, 2016-19 I.R.B. 741 2016-19, 2016-19 I.R.B. 741 2016-20, 2016-21 I.R.B. 991 2016-22, 2016-24 I.R.B. 1028

Notices:

2016-1, 2016-2 I.R.B. 265 2016-2, 2016-2 I.R.B. 265 2016-3, 2016-3 I.R.B. 278 2016-4, 2016-3 I.R.B. 279 2016-5, 2016-6 I.R.B. 302 2016-6, 2016-4 I.R.B. 287 2016-7, 2016-5 I.R.B. 296 2016-8, 2016-6 I.R.B. 304 2016-9, 2016-6 I.R.B. 306 2016-10, 2016-6 I.R.B. 307 2016-11, 2016-6 I.R.B. 312 2016-12, 2016-6 I.R.B. 312 2016-13, 2016-7 I.R.B. 314 2016-14, 2016-7 I.R.B. 315 2016-15, 2016-13 I.R.B. 486 2016-16, 2016-7 I.R.B. 318 2016-17, 2016-9 I.R.B. 358 2016-18, 2016-9 I.R.B. 359 2016-19, 2016-9 I.R.B. 362 2016-20, 2016-9 I.R.B. 362 2016-21, 2016-12 I.R.B. 465 2016-22, 2016-13 I.R.B. 488 2016-23, 2016-13 I.R.B. 490 2016-24, 2016-13 I.R.B. 492 2016-25, 2016-13 I.R.B. 493 2016-26, 2016-14 I.R.B. 533 2016-27, 2016-15 I.R.B. 576 2016-28, 2016-15 I.R.B. 576 2016-29, 2016-18 I.R.B. 673 2016-30, 2016-18 I.R.B. 676

Notices:—Continued

2016-31, 2016-23 I.R.B. 1025 2016-32, 2016-21 I.R.B. 878 2016-33, 2016-22 I.R.B. 1013 2016-34, 2016-22 I.R.B. 1016

Proposed Regulations:

REG-103380-05, 2016-16 I.R.B. 614 REG-118867-10, 2016-10 I.R.B. 411 REG-147310-12, 2016-7 I.R.B. 336 REG-150349-12, 2016-11 I.R.B. 440 REG-138344-13, 2016-4 I.R.B. 294 REG-123867-14, 2016-12 I.R.B. 484 REG-125761-14, 2016-7 I.R.B. 322 REG-135734-14, 2016-18 I.R.B. 712 REG-135734-14, 2016-20 I.R.B. 854 REG-100861-15, 2016-8 I.R.B. 356 REG-108060-15, 2016-17 I.R.B. 636 REG-109822-15, 2016-14 I.R.B. 535 REG-114307-15, 2016-21 I.R.B. 1006 REG-127199-15, 2016-21 I.R.B. 1007 REG-127561-15, 2016-21 I.R.B. 991 REG-127923-15, 2016-12 I.R.B. 473 REG-129067-15, 2016-10 I.R.B. 421 REG-133673-15, 2016-18 I.R.B. 697 REG-134122-15, 2016-7 I.R.B. 334 REG-101701-16, 2016-9 I.R.B. 368

Revenue Procedures:

2016-1, 2016-1 I.R.B. 1 2016-2, 2016-1 I.R.B. 102 2016-3, 2016-1 I.R.B. 126 2016-4, 2016-1 I.R.B. 142 2016-5, 2016-1 I.R.B. 188 2016-6, 2016-1 I.R.B. 200 2016-7, 2016-1 I.R.B. 239 2016-8, 2016-1 I.R.B. 243 2016-10, 2016-2 I.R.B. 270 2016-11, 2016-2 I.R.B. 274 2016-13, 2016-4 I.R.B. 290 2016-14, 2016-9 I.R.B. 365 2016-15, 2016-11 I.R.B. 435 2016-16, 2016-10 I.R.B. 394 2016-17, 2016-11 I.R.B. 436 2016-18, 2016-17 I.R.B. 635 2016-19, 2016-13 I.R.B. 497 2016-20, 2016-13 I.R.B. 499 2016-21, 2016-14 I.R.B. 533 2016-22, 2016-15 I.R.B. 577 2016-23, 2016-16 I.R.B. 581 2016-24, 2016-18 I.R.B. 677 2016-25, 2016-18 I.R.B. 678 2016-26, 2016-22 I.R.B. 1018 2016-27, 2016-19 I.R.B. 725 2016-28, 2016-20 I.R.B. 853 2016-29, 2016-21 I.R.B. 880 2016-30, 2016-21 I.R.B. 981 2016-31, 2016-21 I.R.B. 988 2016-32, 2016-22 I.R.B. 1019

Revenue Rulings:

2016-1, 2016-2 I.R.B. 262 2016-2, 2016-4 I.R.B. 284 2016-3, 2016-3 I.R.B. 282 2016-4, 2016-6 I.R.B. 299 2016-5, 2016-8 I.R.B. 344 2016-6, 2016-14 I.R.B. 519 2016-7, 2016-10 I.R.B. 391 2016-8, 2016-11 I.R.B. 426 2016-9, 2016-14 I.R.B. 530 2016-10, 2016-15 I.R.B. 545 2016-11, 2016-19 I.R.B. 717 2016-13, 2016-23 I.R.B. 1022

Treasury Decisions:

9745, 2016-2 I.R.B. 256 9746, 2016-14 I.R.B. 515 9748, 2016-8 I.R.B. 347 9749, 2016-10 I.R.B. 373 9750, 2016-10 I.R.B. 374 9751, 2016-10 I.R.B. 379 9752, 2016-10 I.R.B. 385 9753, 2016-11 I.R.B. 426 9754, 2016-11 I.R.B. 432 9755, 2016-12 I.R.B. 442 9756, 2016-12 I.R.B. 450 9757, 2016-12 I.R.B. 462 9759, 2016-15 I.R.B. 545 9760, 2016-15 I.R.B. 564 9761, 2016-20 I.R.B. 743 9762, 2016-19 I.R.B. 718 9763, 2016-20 I.R.B. 800 9764, 2016-20 I.R.B. 803 9765, 2016-20 I.R.B. 814 9766, 2016-21 I.R.B. 855 9767, 2016-21 I.R.B. 857 9768, 2016-21 I.R.B. 862 9769, 2016-23 I.R.B. 1020

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–27 through 2015–52 is in Internal Revenue Bulletin 2015–52, dated December 28, 2015.

June 13, 2016 ii Bulletin No. 2016–24

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2016–1 through 2016–24

Announcements:

2007-21 Modified by Ann. 2016-1, 2016-3 I.R.B. 283

Notices:

2005-50 Modified by Notice 2016-2, 2016-2 I.R.B. 265

2007-59 Revoked by Notice 2016-16, 2016-7 I.R.B. 318

2013-29 Clarified by Notice 2016-31, 2016-23 I.R.B. 1025

2013-46 Clarified by Notice 2016-31, 2016-23 I.R.B. 1025

2013-54 Supplemented by Notice 2016-17, 2016-9 I.R.B. 358

2014-79 Superseded by Notice 2016-1, 2016-2 I.R.B. 265

2015-25 Modified by Notice 2016-31, 2016-23 I.R.B. 1025

2015-52 Supplemented by Notice 2016-17, 2016-9 I.R.B. 358

2015-87 Supplemented by Notice 2016-17, 2016-9 I.R.B. 358

2016-60 Modified by Notice 2016-31, 2016-23 I.R.B. 1025

Revenue Procedures:

1987-24 Superseded by Rev. Proc. 2016-22, 2016-15 I.R.B. 577

2003-36 Superseded by Rev. Proc. 2016-19, 2016-13 I.R.B. 497

Revenue Procedures:—Continued

2009-14 Modified by Rev. Proc. 2016-30, 2016-21 I.R.B. 981

2009-14 Superseded by Rev. Proc. 2016-30, 2016-21 I.R.B. 981

2014-56 Superseded by Rev. Proc. 2016-20, 2016-13 I.R.B. 499

2014-64 Supplemented by Rev. Proc. 2016-18, 2016-17 I.R.B. 635

2015-1 Superseded by Rev. Proc. 2016-2, 2016-1 I.R.B. 1

2015-2 Superseded by Rev. Proc. 2016-2, 2016-1 I.R.B. 102

2015-3 Superseded by Rev. Proc. 2016-3, 2016-1 I.R.B. 126

2015-5 Superseded by Rev. Proc. 2016-5, 2016-1 I.R.B. 142

2015-7 Superseded by Rev. Proc. 2016-7, 2016-1 I.R.B. 188

2015-8 Superseded by Rev. Proc. 2016-8, 2016-1 I.R.B. 200

2015-9 Superseded by Rev. Proc. 2016-5, 2016-1 I.R.B. 239

2015-10 Superseded by Rev. Proc. 2016-10, 2016-2 I.R.B. 270

2015-14 Amplified by Rev. Proc. 2016-29, 2016-21 I.R.B. 880

2015-14 Modified by Rev. Proc. 2016-29, 2016-21 I.R.B. 880

2015-19 Amplified by Rev. Proc. 2016-23, 2016-16 I.R.B. 581

Revenue Procedures:—Continued

2015-19 Modified by Rev. Proc. 2016-23, 2016-16 I.R.B. 581

2015-22 Superseded by Rev. Proc. 2016-8, 2016-01 I.R.B. 243

2015-34 Modified by Rev. Proc. 2016-27, 2016-19 I.R.B. 725

2015-34 Supplemented by Rev. Proc. 2016-27, 2016-19 I.R.B. 725

2015-50 Supplemented by Rev. Proc. 2016-18, 2016-17 I.R.B. 635

2015-53 Modified by Rev. Proc. 2016-11, 2016-2 I.R.B. 274

2016-1 Modified by Rev. Proc. 2016-30, 2016-21 I.R.B. 981

Revenue Rulings:

2005-3 Modified by Rev. Rul. 2016-8, 2016-11 I.R.B. 426

2008-15 Revoked by Rev. Rul. 2016-3, 2016-3 I.R.B. 282

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–27 through 2015–52 is in Internal Revenue Bulletin 2015–52, dated December 28, 2015.

Bulletin No. 2016–24 iii June 13, 2016

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