Officers, trustees, directors beware! IRS-imposed 'intermediate' sanctions can be severe.

The IRS pushed for intermediate sanctions for some time. It now has them, and we should assume that it will use them. If you're an insider to a 501(c)(3) or 501(c)(4) organization, who is compensated by or has business dealings with the organization, or if you are an officer, director, or trustee of such an organization, study the intermediate sanctions law and congressional comment on it. Think through its possible applications and ramifications. With the assistance of legal counsel, you may also want to carefully review your organization's indemnification policies and understand how they relate to intermediate sanctions taxes. Finally, keep your ear to the ground for further IRS interpretations and application of this important new tax law.