Michael Peregrine was quoted in the September 14 issue of Tax Notes Today regarding the IRS's released proposed regulations that seek to explain the circumstances under which the IRS will both impose intermediate sanctions and revoke tax-exempt status when excess benefit transactions involving exempt organizations occur. Mr. Peregrine said the proposed regulations will "raise the stakes" on the substance of an exempt organization's intermediate sanctions review process. He pointed out that now, for the first time, an exempt organization can be liable for excess benefit transactions by losing exemption; until now only the transaction participants were penalized. "That will back up general counsel who advise their clients to closely scrutinize potential excess benefit transactions," he predicted.