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UK charities seeking opinions on their equivalency to US tax-exempt charities

Overview

On 2 October 2017, the IRS provided guidance to US tax advisers for issuing opinions to the effect that a non-US charity is equivalent to an analogous tax-exempt US charity (Rev. Proc. 2017-53, 2017-40 IRB 263). 


 

Under this welcome guidance, those UK charities without IRS determination letters will find it easier to receive ‘equivalency opinions' from US tax advisers, and so will access the benefits of such status more swiftly.

 

This article discusses the principal benefits as well as the purposes by which UK charities (without IRS determination letters) can be issued equivalency opinions, and also examines Revenue Procedure 2017-53 in detail.

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