1. ACTION NEEDED: Template Support Letters Available for Proposed Regulations on GWE and Tribally Chartered Corporations
Template Letter for Tribal General Welfare Benefits NPRM
Deadline: January 3, 2025, at 11:59 p.m. Alaska Time
NAFOA has prepared a template support letter for comments on the Dear Tribal Leader Letter regarding the NPRM titled “Tribal General Welfare Benefits.” This proposed rule aims to provide clarity and guidance on tribal general welfare benefits. The template highlights key provisions of the proposed regulations and urges Treasury to provide additional guidance on trust arrangements, federal assistance interactions, and effective implementation support.
Template Letter for Tax Status of Wholly Owned Tribal Entities
Deadline: January 21, 2025, at 11:59 p.m. Alaska Time
NAFOA has also created a separate template support letter for submitting comments on the proposed rule regarding the tax status of wholly owned Tribal entities. This rule aims to clarify the federal income tax status of these entities and expand Tribal access to clean energy tax credits. The template emphasizes support for the rule and calls for further guidance, particularly concerning subsidiary and partially owned entities.
Download Tribally Chartered Corporations Letter>>
2. BLOG POST: Full Circle: Dahlton Brown Reflects on NAFOA’s Life-Changing Impact
By Dahlton Brown
As we close out the year, I want to reflect on what it meant to return to NAFOA this past fall as a sponsor for the 2024 Fall Finance and Tribal Economies Conference. Looking back, I cannot help but consider just how impactful this organization has been on my life. Without exaggeration, NAFOA changed my life with a single phone call.
In 2009, shortly after Wilton Rancheria, my father’s Tribal community, gained federal recognition, I learned about NAFOA and its partnership with the LEAD Summer Business Institute through a professional connection. I applied for a scholarship and was selected to attend the program, which focused on Tribal sovereignty, economic development, and governance.
Originally, I was set to attend the program at Dartmouth College—an exciting prospect for a teenager from Northern California. However, then-NAFOA staff called and offered me to attend the same program but at Stanford University, much closer to home. Of course, I said yes, although I did not have a single clue about Stanford.
3. COMMUNITY: Stakeholder Participation in User Acceptance Testing of New Subaward Reporting System
The Council on Federal Financial Assistance (COFFA) understands the importance of stakeholder engagement to improve policies and systems within the federal financial assistance community. As part of this effort, COFFA invites participation in testing a new subaward reporting system.
The Government Services Administration (GSA) plans to decommission the current Federal Subaward Reporting System (FSRS.gov) and transition to a new system on the System for Award Management (SAM.gov) by March 2025.
COFFA seeks assistance in identifying stakeholders familiar with FSRS and subaward reporting to participate in user acceptance testing (UAT) of the new system and provide feedback.
UAT has already begun, and prompt participation is needed. To register for UAT, stakeholders can request access by emailing SAMTesting@gsa.gov.
Source: Council of Federal Financial Assitance
4. MUST READ: Experts break down game-changing tribal tax rule during NAFOA webinar
Tribes need to weigh in regarding a recent Treasury rule change that certified wholly owned tribal enterprises as tax-exempt, clarifying more than 30 years of murky policy.
That message dominated a NAFOA webinar Thursday, Dec. 12. Telly Meier, partner at law firm Hob Strauss Dean & Meier, spoke alongside Ken Parsons, partner at law firm Holland & Knight. They outlined a history of tribal tax exemption and the way the new rule would interact with tribal LLCs and other kinds of corporate entities.
The rule change establishes first-time certainty for tribal enterprises, per previous Tribal Business News reporting. It creates a vehicle that tribes can use to apply for elective-pay tax credits for renewable energy projects under the Inflation Reduction Act. These entities can be treated as instrumentalities of the tribe and file directly for the credits, rather than requiring the tribe itself to do so.
Meier and Parsons both pointed to an upcoming comment period as an opportunity to reinforce that this kind of progress was what tribes needed from the IRS, even amid an upcoming administration change. The written comment period will be open until Jan. 7, 2025. The IRS will host virtual tribal consultations on Dec. 16-18 and a public hearing Jan. 17 at the IRS building in Washington, D.C
Source: Tribal Business News
5. JOBS: Treasurer, Cheyene-Arapaho Tribes of Oklahoma
The Treasurer is under the direct supervision of the Chief of Staff. The Treasurer directs and manages the activities and operations of the Tribes including financial planning and analysis practices, purchasing, budgeting, accounting, debt and project management; reserve policy, and treasury services and activities; to coordinate assigned activities and complex administrative support to the Executive Office. The Treasurer will maintain a wholesome and favorable relationship with the Tribal Members, Legislators, Executive Directors, Program Directors/Coordinators, and Employees.
Have something to share with the NAFOA community? Share an entry in the “5 Things” Newsletter
Get NAFOA’s 5 Things You Need to Know This Week in your inbox at the start of each week: Subscribe.
