Case No. SY-2016-326022-1

Date issued: Jul. 16 2018

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TURBOFAC Commentary (594 words)

Notes:

1) Background

The applicant for this guidance letter, “Syrian American Wish Association Inc.” is/was a New York not for profit corporation that was granted tax-exempt status by IRS in May 2015. The entity appears to have never filed a tax return (indicating no economic activity). (https://projects.propublica.org/nonprofits/organizations/473918211).

At the time the guidance request was made, 542.516(a) of the SySR provided that “Nongovernmental organizations are authorized to export or reexport services to Syria that would otherwise be prohibited by § 542.207 in support of the following not-for-profit activities…Activities to support humanitarian projects to meet basic human needs in Syria, including, but not limited to, drought relief, assistance to refugees, internally displaced persons, and conflict victims, food and medicine distribution, and the provision of health services…” 542.516(b) provided that “U.S. depository institutions, U.S. registered...