Exempt Organizations Advisory - IRS Releases Interim Report on College and University Compliance Project

Catherine W. Wilkinson (cwilkinson@steptoe.com)
Suzanne Ross McDowell (smcdowell@steptoe.com)

In October 2008, the Exempt Organization Division of the IRS sent surveys to 400 public and private four year colleges and universities as part of the Colleges and Universities Compliance Project. The survey requested information regarding the entities’ operations, endowments, international activities, compensation, unrelated business income, and governance. Today the IRS has released the interim report on this project. The report provides preliminary information about the data received from these entities, with responses divided into categories for small, medium, and large colleges and universities. The IRS is currently conducting examinations of some of the organizations that received the survey, with a focus primarily on unrelated business income and executive compensation issues. Organizations that failed to respond to the survey were also referred to EO Examination. The IRS expects to provide a final report that includes information from both the examinations and further analysis of the survey data. A major purpose of this project is to identify issues that require more guidance and scrutiny from the IRS.

The full report is available here.