Child Advocates Seek Quick Action on SALT Cap Regs

PUBLIC SUBMISSION

Docket: IRS-2019-0056
Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)

Comment On: IRS-2019-0056-0001
Treatment of Payments to Charitable Entities in Return for Consideration

Document: IRS-2019-0056-0024
Comment from Betsy Fanning,

Submitter Information

Name: Betsy Fanning

Address:

Email: bfanning@tridentacademy.com

Phone: 8438847046111

General Comment

First and foremost, let me thank you for clarifying your December ruling on business deductions with the "Treatment of Payments to Charitable Entities in Return for Consideration".

As a board member for Exceptional SC, a scholarship granting organization in SC designed to raise funds and distribute them in the form of grants to exceptional needs students, I am grateful for the changes.

Changes to the tax law that were intended to reign in states that wanted to bypass tax reform have greatly impacted our ability to help special needs students in South Carolina. Our program was already doing what tax reform intended and that was re-directing tax dollars into a program for exceptional needs children that public schools could not accommodate.

Exceptional SC is capped at $12 million, doesn't use tax money and is not guaranteed, so our board has to raise the money each year.

The confusion created by the ruling has frozen financial advisors and accountants who have advised their clients that they should not give to our program any longer.

Your ruling in December on business deductions was very helpful and we appreciate you clarifying that and earnestly desire that you finalize that ruling quickly so that pass-through entity businesses CAN take the federal deduction for donations to our program.

Thank you for the changes! Freeing up SC businesses to help special needs children is a wonderful thing!

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 PUBLIC SUBMISSION

Docket: IRS-2019-0056
Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)

Comment On: IRS-2019-0056-0001
Treatment of Payments to Charitable Entities in Return for Consideration

Document: IRS-2019-0056-0018
Comment from Kristin Scott,

Submitter Information

Name: Kristin Scott

General Comment

I am a parent of two children — one of whom received the Exceptional SC scholarship for 5 years and one who has been receiving it for 2 years. Both of our children have a learning disability called dysgraphia which impacts their ability to visualize, make sense of and copy or write information. Dysgraphia makes it very difficult for students to keep up with notes, copy instructions, multitask and effectively engage in a classroom environment at a normal pace. We have been very fortunate to enroll our children in Our Lady of the Rosary's Arrowsmith program which provides a specialized program to help students overcome specific learning disabilities and provide a supportive learning environment. The Exceptional SC scholarship made it possible for us to enroll both of our children and take advantage of this life changing program.

Changes to the tax law that were intended to reign in states that wanted to bypass tax reform have greatly impacted SC's program. This program was already doing what tax reform intended and that was re-directing tax dollars into a program for exceptional needs children that public schools could not accommodate. Our program is only $12 million and DOESN'T use tax money and is not guaranteed, so our program has to raise the money each year.

The confusion created by the ruling has frozen financial advisors and accountants who have advised their clients that they should not give to our program any longer.

Your ruling this week on business deductions was very helpful and we appreciate you clarifying that and earnestly desire that you finalize that ruling quickly so that pass through entity businesses CAN take the federal deduction for donations to our program.

We hope that you will take the needed steps to resolve this confusion. Thank you for your time and consideration as this funding provides children with disabilities in SC access to life changing academic opportunities.

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PUBLIC SUBMISSION

Docket: IRS-2019-0056
Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)

Comment On: IRS-2019-0056-0001
Treatment of Payments to Charitable Entities in Return for Consideration

Document: IRS-2019-0056-0012
Comment from Mark McClure,

Submitter Information

Name: Mark McClure

General Comment

Please give back the deduction for individuals and keep for businesses!

Changes to the tax law that were intended to reign in states that wanted to bypass tax reform have greatly impacted SC's program.

This program was already doing what tax reform intended and that was re-directing tax dollars into a program for exceptional needs children that public schools could not accommodate.

Our program is only $12 million and DOESN'T use tax money and is not guaranteed, so our program has to raise the money each year.

The confusion created by the ruling has frozen financial advisors and accountants who have advised their clients that they should not give to our program any longer.

Your ruling this week on business deductions was very helpful and we appreciate you clarifying that and earnestly desire that you finalize that ruling quickly so that pass through entity businesses CAN take the federal deduction for donations to our program.

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 PUBLIC SUBMISSION

Docket: IRS-2019-0056
Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)

Comment On: IRS-2019-0056-0001
Treatment of Payments to Charitable Entities in Return for Consideration

Document: IRS-2019-0056-0020
Comment from Michelle Keiffer,

Submitter Information

Name: Michelle Keiffer

Address:

General Comment

I am both a parent of a child and teacher of children who receive the Exceptional SC scholarship. My child has received funding through this program for 5 years — and it has made a life-changing difference for him and our entire family. We had i large extent 'lost' our son after moving to SC and realizing the public schools were not equipped to teach students with dyslexia. We knew 'what' our son needed to thrive, but in the Midlands, the ONLY place that offered the services he needed was Sandhills School — which specializes in students with dyslexia and we simply could not afford the tuition. While it is still a significant financial sacrifice, our son is receiving effective instruction that has restored his self-confidence and love of learning. He is now an honor roll high school student that is thriving! We are deeply concerned that this program continues for our son's sake — and the MANY students (approximately 1:5) that we KNOW learn differently. Please help!

Changes to the tax law that were intended to reign in states that wanted to bypass tax reform have greatly impacted SC's program.

This program was already doing what tax reform intended and that was re-directing tax dollars into a program for exceptional needs children that public schools could not accommodate.

Our program is only $12 million and DOESN'T use tax money and is not guaranteed, so our program has to raise the money each year.

The confusion created by the ruling has frozen financial advisors and accountants who have advised their clients that they should not give to our program any longer.

Your recent ruling on business deductions was very helpful and we appreciate you clarifying that and earnestly desire that you finalize that ruling quickly so that pass through entity businesses CAN take the federal deduction for donations to our program.

This program is such a blessing to so many! Please help us keep it operational!!!

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PUBLIC SUBMISSION

Docket: IRS-2019-0056
Treatment of Payments to Charitable Entities in Return for Consideration (REG-107431-19)

Comment On: IRS-2019-0056-0001
Treatment of Payments to Charitable Entities in Return for Consideration

Document: IRS-2019-0056-0004
Comment from Ashley Brooks,

Submitter Information

Name: Ashley Brooks

General Comment

To Whom It May Concern,

I am a parent of a special needs child in South Carolina, who receives Exceptional SC scholarship funds. Without this financial assistance, our family would be unable to get our son the educational support he needs. These funds are crucial to our son's future and well-being.

Recent changes to the Federal tax law that were intended to reign in states that wanted to bypass tax reform, have greatly impacted SC's program. The Exceptional SC program was already doing what tax reform intended and was re-directing tax dollars into a program for exceptional needs children that public schools could not accommodate. Exceptional SC is capped at only $12 million, DOESN'T use tax money and is not guaranteed, so this critical program has to raise the money each year.

The confusion created by the recent ruling has frozen financial consultants and accountants who have advised their clients that they should not give to our program any longer. Your ruling this week on business deductions was very helpful and we appreciate you clarifying that and earnestly desire that you finalize that ruling quickly so that pass through entity businesses CAN take the federal deduction for donations to our program.

Thank you for your time and consideration,

Ashley Brooks