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TAHAWK

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Posts posted by TAHAWK

  1. From IRS.GOV 01/25/2020:

    "INTERNAL REVENUE SERVICE Number: INFO 2002-0041

    Release Date: 3/29/2002 February 15, 2002

    UIL: 501.03-08 501.33-00

    [REDACTED] xxxxxxxxxxxxxxxxx

    xxxxxxxxxxxxxxxxxxxxxx

    xxxxxxxxxxxxxxxxxxxxxx

    xxxxxxxxxxxxxxxxxxxxxxxxxxx

    Re: xxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

    Dear Mr. xxxxxx:

    We received your recent letter requesting information regarding a program you are considering adopting within your xxxxx Scout Pack. You indicate that your Pack is xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx tax exempt under section 501(c)(3) of the Internal Revenue Code. One of the purposes of the Scouting program is to instill self-reliance ixxxxxxxxxx. You indicate that one way of doing this is to allow the xxxxxx to earn their own way as opposed to depending on others, including their parents, to fund their individual scouting participation.

    To further this self-reliance, you are proposing to allow the xxxxxx in your Pack to raise monies through fundraising activities and to designate the use of some of these funds to pay for personal expenses. These expenses would include 1) Scouting fees such as organization dues and camp registration fees; 2) items used exclusively for Scouting such as uniforms and Scouting books; and 3) items used primarily for Scouting such as camping equipment.

    Using the money raised in various fundraising activities to further the Scouting program for all of the xxxxxx in your Pack is in accordance with your exempt purposes xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. In this regard, the Pack could use the funds (all or a percentage) it raises to reduce or eliminate dues and various registration fees, purchase uniforms and Scouting books and purchase camping equipment. The Pack could also use its funds to provide assistance to individual Scouts in cases of financial hardship.

    The distribution method you are proposing - the creation of a reserve fund within the Pack where a portion of the money that an individual Scout raises during a fundraising 2 event is reserved for xxx use alone, is a troublesome one. Earmarked accounts may not be compatible with continued tax exemption. Such a decision cannot be made without considering all of the facts and circumstances. Accordingly, we are not ruling definitively at this time. We hope the following general discussion will be helpful.

    Section 501(c)(3) of the Code provides, in part, an exemption to the federal income tax for organizations organized and operated exclusively for educational, charitable or other exempt purposes. Under the Income Tax Regulations, an organization will be considered operated exclusively for exempt purposes if it engages primarily in activities which accomplish those purposes. If more than an insubstantial part of an organization's activities do not further its exempt purposes, it will not be considered operated exclusively for exempt purposes. In addition, an exempt organization must serve a public rather than a private interest. Thus, an organization must establish that it is not organized or operated for the benefit of private interests, such as designated individuals.

    The private benefit prohibition is broad and includes the individual Scouts and their parents. The amount of private benefit that will be permitted depends on the magnitude of that benefit in relation to the public benefit derived from the organization's activities and whether that private benefit is necessary for the organization to achieve its exempt purposes. In considering whether a private benefit, such as earmarked accounts for the personal benefit of individual Scouts, is substantial enough to jeopardize your exemption, one must examine all of the facts and circumstances. In relation to the public benefit inherent in the Scouting program, this may be a small private benefit. Whether the private benefit to the individual Scouts is necessary to achieve the goals of the Scouting program, however, is not clear.

    We discussed a similar question in regard to athletic booster clubs that earmarked a portion of their fundraising proceeds to be shared only by the members who participated in the fundraiser in the 1993 CPE text (a copy is attached for your convenience). In the hypothetical addressed in the Article (Example one on page 5), we determined that the resulting private benefit to the individual members was substantial and negated the charitable intent of the organization precluding exemption under section 501(c)(3) of the Code.

    You have asked whether issuing a Form 1099 for each Scout receiving such benefits would negate the private benefit question. In this case, you would treat all income the Scout receives through the earmarked account as compensation for tax purposes. An exempt organization can, of course, pay reasonable compensation for services. Treating the receipts as income to the individual, however, may raise additional issues for the Pack. In particular, the fundraising activity may, if conducted by paid labor rather than volunteers, be characterized as unrelated business income taxable under section 3 511 of the Code. You may wish, therefore, to consider whether creating a possible tax liability for both the individual Scouts and the Pack is appropriate under the circumstances.

    This letter is advisory only and has no binding effect on the Internal Revenue Service. The information provided here cannot be relied upon as a ruling on the matters discussed. If you have any questions regarding this discussion or we can be of further assistance, please feel free to call me at 202-283-8926 or Ms. xxxxxxxxxxxxx at xxxxxxxxxxxx.

    Sincerely, /s/ Gerald V. Sack Gerald V. Sack Manager,

    Exempt Organizations Technical Group 4"

     

  2. BSA policy is, for BSA especially, pretty clear, as is the policy barring troop neckerchiefs not approved by council and not of identical size and  triangle shape as official BSA-sold neckerchiefs.  Perhaps fewer rules, and those  reasonable and enforced, would make more sense for BSA and IRS.

    The IRS has had very drastic funding cuts over the last seven years and is relying on obsolete computers and software more and more.  IRS is  also the second most unpopular federal agency with voters - only VA gets worse marks, and VA is perceived as killing veterans. 

    INDIVIDUAL SCOUT ACCOUNTS AND FUNDRAISING BY BSA UNITS -  Frequently Asked Questions  (2/11/2014)

    "Are individual Scout accounts permitted? Yes. These accounts are permitted when funded by the youth member through savings, a portion of a weekly allowance, and chores around the home and neighborhood. The youth member’s family may contribute, but no charitable deduction is allowed.

    What is private benefit, and why is it not allowed? Private benefit is when funds raised in the name of Scouting or another charity are directly allocated to the youth member or family doing the fundraising. Funds raised in the name of Scouting should benefit the entire unit. The tax laws do not permit private benefit, with the exception of an “insubstantial” benefit.

    How is an “insubstantial” benefit defined? The IRS has classified 30 percent of the money raised as “substantial,” and less than 2 percent as “insubstantial.” The burden of proof that the benefit is “insubstantial” is on the organization. Are incentives allowed for participation in fundraising or sales? The IRS has not ruled on this matter, but the “insubstantial” benefit restriction would apply.

    Can Scouting units use funds to assist youth members who have a financial need? The unit can allocate funds based on financial need, and may consider factors such as participation in the unit, advancement, and Scout spirit.

    Are there penalties for private benefit or other tax issues? Private benefit may result in the loss of tax-exempt status for the chartering organization, or the local council. Allocating funds raised in the name of Scouting directly to a youth member could result in self-employment tax liability.

    Questions? Please contact your local council. Thanks for all that you do."

    For what it's worth, recalling that square troop neckerchiefs and distinctive patrol neckerchiefs are a definite "no-no": 

    https://blog.scoutingmagazine.org/2014/12/03/individual-scout-accounts/ ("What’s definitely not OK.  Money raised in the name of Scouting that isn’t used for Scouting is a definite no-no.")  😢

     

     

  3. 2 hours ago, Pale Horse said:

    Yeah, I'm not sure what you're trying to say here. 

    If you think that quote is requiring all parents to attend camping activities, you should keep reading: both the next couple paragraphs of GTSS and the rest of this thread which clear up any confusion.

    I think it means no more than it says.  if you believe I have quoted out of context, by all means supply the context rather than your opinion.  

    This thread, including any opinions I might post,  is not the official "word" of BSA.

  4. On 1/22/2020 at 1:18 PM, Pale Horse said:

    NO.  BSA rules do not require a parent or guardian unless the Scout is a Tiger or Lion.  Refer to Guide to Safe Scouting which @T2Eagle quoted above.  Councils are able to set their own requirements at Council Events, but that is not a BSA rule and cannot be enforced at non-council events.

     

    Age Guidelines 

    The Boy Scouts of America has established the following guidelines for its members’ participation in camping activities:

    • Overnight camping by Lion, Tiger, Wolf, or Bear Cub Scouts as dens is prohibited. Webelos dens may participate in overnight camping.
    • Lions, with their adult partner, may participate in child-parent excursions, pack overnighters, and council-organized family camping.
    • Tigers, with their adult partner, may participate in child-parent excursions, day camps, pack overnighters, council-organized family camping, or resident camping.
    • Tiger, Wolf, and Bear Cub Scouts, and Webelos Scouts may participate in a resident overnight camping program operating under BSA National Camping School–trained leadership and managed by the council.
    • Den leaders, pack leaders, and parents are expected to accompany the youth on approved trips.
    • Thanks 1
  5. 2 hours ago, ValleyBoy said:

     

    At different times we have got mixed signals from my local council on what is allowed and not allowed under GTSS when it comes to the scouting program.  The interpretation within my council on cub scout camping is that all cubs below webelos  have to have a parent, relative over the age of 18, or guardian ( foster parent) with them when camping overnight except for council/district overnight lock-ins.

    That is what the BSA rules expressly require - in so many words.  

  6. "Congratulations to Kenn Miller, who will serve as Scout executive of the Baltimore Area Council in Baltimore, Maryland, effective January 15, 2020.

    Kenn began his Scouting career as a district executive and then field director of the Northeast Illinois Council in Highland Park, Illinois. He was promoted to director of field service of the Lincoln Heritage Council in Louisville, Kentucky, and then selected as Scout executive of the Black Swamp Area Council in Findlay, Ohio. He moved on to serve as the Scout executive of the Greater Cleveland Council in Cleveland, Ohio, before joining the Central Region staff as deputy regional director. Kenn was then selected to serve as the Scout executive of the Heart of America Council in Kansas City, Missouri. Since March 2018, Kenn has served as the director of program & operations at the Summit Bechtel Reserve in Glen Jean, West Virginia.

    Kenn is an Eagle Scout from Allentown, Pennsylvania. He is a Vigil Honor member of the Order of the Arrow and enjoys camping, golf, sporting clays, and being involved in community activities.

    Kenn and his wife, Laura, have three grown children, two daughters and a son who is an Eagle Scout. Kenn and Laura are expecting their first grandchild in January.

    In the comments below, please help us welcome Kenn to his new role in the BSA as he joins in partnership with the volunteers and staff of the Baltimore Area Council to deliver quality Scouting experiences to the young people of the communities they serve."

     

    Anyone else have experiences with Kenn?

  7. 4 hours ago, ParkMan said:

    I would think it would be in the church's best interest to simply let the LGBTQ issues be a local or regional choice.  It reminds me of the similar BSA issues.  Because the BSA took a stand on the question at a national level, it became a topic to argue over . But, if the BSA had simply said that it is a topic which can be decided locally, it would have saved years of arguing.

    So, here you have a social issue that the world is grappling with.  If the church put the responsibilty on the individual churches to handle it as they believe best, it would allow the church to remain whole.  

     

    That solution is intolerable to those wanting a change in policy, according to their writing on the subject.

  8. 8 hours ago, vol_scouter said:

    From people who would know, the BSA does provide positive, supportive information but the news media usually chooses not to include those comments. 

    The news media seems to have a point of view on many (most?) articles and provides only the information supporting their point of view.

    When it comes to science topics of which I am familiar or an expert, the news media never gets a story entirely correct. No sure if that is from a point of view or lack of knowledge but it is wrong. 

    The BSA is trying to get positive information out through responses to articles such as this and news articles that the media simply refuses to publish. Advertising has enormous costs.

    Journalism, in the sense of  energetic investigation and a drive for accuracy, died decades ago with few exceptions.  Now it's "He said"/"She said"  and "If it bleeds, it leads."

    CNN initially reported in its on-line version that the attack in Baghdad that killed  Soleimani was by "three Katyusha rockets."  I contacted them and pointed out that those rockets are WW II-era ballistic rockets - unguided  area weapons - very inaccurate and that the U.S. doesn't use them.  The story then changed to "drone attack."   This was a big deal story and a hash was made of it right out of the gate.  The claim of Katyushas suggested an attack by ISIS or some other group opposed to Iran, and, given that it was CNN, anything was possible.

    Our local remaining, dying newspaper, reported a few years ago that Jews and Muslims are offended by the public display of the Ten Commandments because "They are from the Christian Bible."  :blink: The story was by their "Chief foreign news editor, who supposedly has a BA in "liberal arts" from Smith. All that education set to naught by the failure to see The Ten Commandments.   My old Honda had a bumper sticker given to me by the Troop SM, a cantor; "Moses says take 10."  Muslims feel they have a better version but are emphatically not offended at what they regard as an older revelation from Allah, since updated by the revelations accorded to the Prophet  Muhammad salla.jpg centuries later.

    Most of the material in the Cleveland Plain Dealer for several years is days-old cut-and-paste  from AP, NY Time, Washington Post, and LA Times.    It employs a fraction of it's former staff.  It mourned the  death of the Cleveland Press.  TV will mourn the death of the "PD"  when life support is discontinued.  

  9. My troop had uniformed female leaders nine years before BSA caught on that disqualifying over half the adult population wasn't helping with the critical shortage of adult volunteers. (Including a retired USMC First Sgt.)   Forty years after recognizing the issue, what is the BSA  "plan" to address the problem of getting more adult volunteers?    Crickets.  :confused:

     

    And if there is an issue of violence from a cheating adult, what is council doing?  This guy should not be around for YPT reasons alone.  Adult Association is supposed to be with adults of integrity.  The son is stuck with him.  (And the same issues arise with Merit Badge mills.  Horrible examples tolerated by councils and BSA for venal reasons.)

  10. Taken as given that anything said can be twisted, the safest course would be to say nothing - or close down.  Even "no comment" is used by the MSM as an admission of quilt.  At the extremes, mere accusation = guilt.

    Advertising is a normal business expense, so long as the work is hired out at arm's length.  

    Sacrificing the core supporters to attempt to mollify enemies is remarkably incompetent.  Those who hate Scouting will never stop attacking until it is destroyed.  The target should be the committed supporters and the uncommitted - those already persuaded or persuadable.

    In classic liberalism, " I disagree with everything you say but defend to the death your right to say it."  We have few liberals around today, especially among those calling themselves "liberals."

     

     

  11. Several years ago, one of our districts overwhelmingly elected a long-service volunteer as DC. 

    The SE vetoed the election,  with no reason given.   Consensus is that elected DC was regarded as insufficiently servile.   The vetoed guy was and is much liked and respected. Every year, there he is every day of Summer Camp, running the Health Lodge (ER  RN). Does really well with kids and adults.  Supernaturally calm in emergencies.

    Another election.  Same guy elected - unanimously this time. Vetoed again.  No reason given.

    Another election.  No one elected DC - no votes for any candidate on slate presented by Council, but guy elected DC twice is unanimously elected ADC on motion from floor  District returns to function under leadership of ADC - leads Council in fund-raising.

    SE retired. 

    New SE eliminates districts in favor of geographic "service teams" run by "professionals." Already poor roundtable attendance and fund-raising both crash, council-wide.  Council listed for consolidation out of existence less than three years after doubling in size.

    Defy the First Law of Holes to your peril.

    Ignorance can be cured.  Stupidity, not so much.

     

    • Upvote 2
  12. It is not  enough that they preside over steady failure?

    OK

    1. I believe that good unit-level program, and nothing else, attracts youth customers for BSA and for Scouting.  BSA seems to focus on everything else, including to the detriment of program.  The first question before anything new is adopted or anything is discontinued should be, "How will this impact sales?"  We need BSA leader who focus on program or we need Scouting to leave BSA.

    2. BSA seems to believe that easily obtained "bling" is the key to membership growth, even as making bling easier to obtain tracks declining membership.  5-7 times as many "Eagles"; summer camp merit badge mills; merit badge  "colleges";  OA for ALL.   It may not be causing membership decline, but it is not correcting it.  It is, rather, the pursuit of illusion.  We need sane and honest leadership at BSA or we need to leave BSA,

    3. BSA focuses on $$ to meet payroll, and risks to that $$$ $$ $,  to the near total exclusion of concern for any other factor.  So, in the four Ohio councils that I have studied since 1981, volunteer positions in the district and council within the gift of the paid Scouters increasingly go to the sources of the biggest donations (See "Good Volunteer") without consideration of performance.  Staff payroll is important, but the obsession is short-sighted.  No customers is the end of the jobs as surely as lack of revenue from begging.     Our Museum account, for which I was Treasurer, went short $2,000 donated to support the Museum.  There was no inquiry.  I was told, "Not to worry. " (I did not worry.  I resigned.)  Gifts to the museum of Scout memorabilia have been sold off to fund payroll. What was that "Trustworthy" thing?  We need leadership at BSA and councils that is trustworthy or we need to leave BSA, lest we be as tainted as they already are.  

    4. For years, lack of adult volunteers has crippled program.  I see no effort to correct this shortage.  Instead, BSA absolutely discourages direct recruiting of adults who do not have youth in the program, even though adults with children no longer in the program are disproportionately volunteers beyond Cubbing.  This is not explained; simply decreed.  (I am told enforcement is uneven.)  Some YPT theory? My friends in Canada, India, Australia, and the Philippines find this policy bizarre.  It is, and it needs to change.  We need more adults. (Donors are, of course, aggressively recruited. I do get monthly appeals for $$$, including "estate planning opportunities." 💀 )

    5. Most of the officials at BSA are unfamiliar with the substance of BSA program "methods."  I have officially asked three times  for guidance on what BSA wants me to teach about the Patrol Method at the district, council, and area levels, because the training syllabii do not approach covering the topic.  They have  not done so for over thirty years - closer to forty-five. BSA is unable to define the Patrol Method since Marc Griffin left Information Delivery several years ago ( and he ran out of time to correct the problem before being transferred, eventually to Salt Lake City to try and save LDS membership).  BSA is too busy with things other than Scouting - things less important to BSA survival, much less important to Scouting.  I tried to discuss with our SE why Leadership, formerly though to be an aspect of citizenship, was a separate "Goal" now.  He was totally confused.  He could not distinguish methods from goals and did not understand the methods.  Leading a "business" that you do not understand produces Sears. It too peddled off assets before the end.

    6. Membership figures in BSA are often false.  Our just-previous SE, an honorable man, had to take a 30% membership hit his first year when he closed down numerous fake units. My home council's first "Executive" was fired over this issue decades ago when 25% of the membership is fake.  The FBI has formally investigated phony membership figures from other councils.  Membership numbers once drove United Way contributions, motivating lying about membership.  It's called "Digging deep for Scouting"  because the liar pays the registration fees to improve his performance metrics.  When I tried to recognize the SMs of my district's two oldest troops some years ago, I found they, and their troops, had been dead for years.  I could not get the crooked DE fired but I got a new DE.  We now have units in one suburb for sure that have not had advancement in many years - none, but they re-register with exactly five youth and three adults every year. I am assured they do not meet.   I went to there "meting place" one "meeting night" and found only the janitor, who knew nothing about Scouits.  Competent, honest leaders demand that the "numbers" be reliable so they can make rational decisions.  The recognition of that need motivated our immediately-past, and honorable, SE to chop heads when the fraudulent numbers did not immediately stop as he had demanded.  Good for him!  Accurate performance numbers are NOT essentia for "pretend" leadership.

     

    • Upvote 4
  13. I quoted predictions.   I assume the Green Machine currently trims it's sails to match the present wind, but it still makes dire predictions. 

     

    The issue for me is damage to the credibility of what I think of as "conservation" - rationally preserving finite resources against waste.  Keep making wildly inaccurate dire predictions, and even the unmistakable truth gets lost.  Neo-Luddites provide noise the profligate can and do use to drown out reasonable concerns.  Then we have the politicians like AOC demanding the outlawing of meat-eating, no more use of fossil-fuel, and, generally, TEOTWAWKI - all to gain power.   See, it is not enough for the Green Machine that one agrees there is climate change - even "global warming" - or agrees that we can make it worse - or better.  The Green Machine demands total obeisance to every aspect of their religion, even if it means ignoring science: "Sun energy output cycles are meaningless!"   👽

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