Text of IRS Notice 2018-99: Parking Expenses for Qualified Transportation Fringes Under Sections 274(a)(4) and 512(s)(7) (PDF)

24 pages. "This notice provides interim guidance for taxpayers to determine the amount of parking expenses for qualified transportation fringes (QTFs) that is nondeductible under Section 274(a)(4) of the Internal Revenue Code and for tax-exempt organizations to determine the corresponding increase in the amount of unrelated business taxable income (UBTI) under Section 512(a)(7) attributable to the nondeductible parking expenses....

"This notice also announces that the [Treasury Department and the IRS] intend to publish proposed regulations under Sections 274 and 512 (and under Section 6012 with regard to the exempt organization's related filing requirement). The proposed regulations will include guidance on the determination of nondeductible parking expenses and other expenses for QTFs and the calculation of increased UBTI attributable to QTFs. Until such guidance is issued, taxpayers and tax-exempt organizations that own or lease parking facilities where their employees park may use any reasonable method, as provided in section B of the Interim Guidance on QTF Parking section of this notice, to determine the amount of nondeductible expenses under Section 274(a)(4) or the amount of the increase in UBTI under Section 512(a)(7). Furthermore, until further guidance is issued, taxpayers may rely on the guidance in this notice to determine the amount of nondeductible parking expenses for QTFs under Section 274(a)(4), and tax-exempt organizations may rely on the guidance in this notice to determine the amount of the increase in UBTI under Section 512(a)(7)."
Internal Revenue Service [IRS]

Text of IRS Notice 2018-100: Relief from Additions to Tax for Underpayment of Estimated Income Tax for Tax-Exempt Organizations That Provide Certain Qualified Transportation Fringes (PDF)

"This notice provides certain tax-exempt organizations a waiver of the addition to tax under section 6655 of the Internal Revenue Code for underpayment of estimated income tax payments required to be made on or before December 17, 2018, to the extent the underpayment of estimated income tax results from the changes to the tax treatment of qualified transportation fringes ... This relief applies to a tax-exempt organization that [1] provides qualified transportation fringes (as defined in section 132(f)) to an employee for which estimated income tax payments ... would otherwise be required to be made on or before December 17, 2018, and [2] was not required to file a Form 990?T, Exempt Organization Business Income Tax Return, for the taxable year preceding the organization's first taxable year ending after December 31, 2017. This relief is limited to tax-exempt organizations that timely file Form 990-T and timely pay the amount reported for the taxable year for which relief is granted."
Internal Revenue Service [IRS]

IRS Issues Guidance for Determining Nondeductible Amount of Parking Fringe Expenses and Unrelated Business Taxable Income; Provides Penalty Relief to Tax-Exempt Organizations (PDF)

"A key part of this guidance is a special rule, enabling many employers to retroactively reduce the amount of their nondeductible parking expenses. Under this rule, employers will have until March 31, 2019, to change their parking arrangements to reduce or eliminate the number of parking spots they reserve for their employees. By making this change, many churches, schools, hospitals and other tax-exempt organizations may be able to reduce their associated UBTI." [Guidance is found in IRS Notice 2018?99 and Notice 2018?100 ]
Internal Revenue Service [IRS]