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Stradley Ronon Attorneys File Additional Comments Recommending Changes to IRS Proposed Revenue Procedure

May 17, 2021
Firm News
PHILADELPHIA – Stradley Ronon is pleased to announce Mark E. Chopko and Jennifer A. Gniady drafted a second comment letter  to the IRS on behalf of eight joint religious denominations as a supplement to their comments that were submitted in August 2020. The new comments address the proposed revenue procedure (Notice 2020-36) regarding the group ruling tax exemption program, and were submitted on behalf of eight religious denominational group ruling holders that represent more than 100,000 tax-exempt entities across the U.S. and its possessions.

The additional comments include an outline of “a specific set of recommendations not only to address the issues with the current proposal but also to make concrete what had persisted for decades: the administration of religious group rulings in a way that accommodated the needs of the Service, but also did not interfere with the constitutionally protected internal governance of the various participating faith communities,” as stated in the comment letter.

The IRS proposal would impose stringent definitions of “supervision or control,” among other changes, that would revoke the traditional accommodation for religious organizations under IRS practice. Chopko and Gniady are representing the group as part of the firm’s pro bono services, and summarize general recommendations and specific modifications to the proposal in their comments. The IRS is continuing to finalize the proposed revenue procedure and is expected to issue final rules in advance of lifting the suspension on new group exemptions.

Chopko chairs Stradley Ronon’s nonprofit and religious organizations practice group and advises clients, including colleges and universities, in matters involving structural, business, governance, regulatory and complex litigation. He specializes in defending religious organizations and teaches a seminar on church-state law at Georgetown University Law Center and is an adjunct in the School of Foreign Service. A former general counsel for the U.S. Conference on Catholic Bishops, he has participated in more than 30 Supreme Court cases as counsel for religious groups in friend-of-the-Court briefs.

Gniady helps nonprofit organizations of all sizes navigate complex legal issues while remaining true to their charitable missions. Her practice combines experience with both tax exemption issues and corporate matters. She works with clients to respond to existing threats and legal issues, while counseling practices to strengthen the organization in the long term. Her clients include charities, religious organizations, associations, schools and arts organizations. Her practice includes forming nonprofit organizations, advising on corporate governance and bylaws, analyzing lobbying and fundraising practices, responding to inquiries from IRS, state, and local charitable regulators and managing litigation.

About Stradley Ronon
Counseling clients since 1926, Stradley Ronon has helped private and public companies – from small businesses to Fortune 500 corporations – achieve their goals by providing pragmatic, value-driven legal counsel. With offices in seven strategic locations, our responsive team of more than 200 attorneys seamlessly addresses the full spectrum of our clients’ needs, ranging from sophisticated corporate transactions to complex commercial litigation.

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