Joint Ventures Involving Tax Exempt Organizations 4e, 2021 - Cumulative Supplemen

Stay up to date on all relevant regulatory and legislative changes, as well as leading case law, in a complicated area of law In the 2021 Cumulative Supplement to the 4th edition of Joint Ventures Involving Tax-Exempt Organizations, a renowned team of authors delivers the latest updates and developments in the legislation, regulations, and case law governing joint ventures with tax-exempt organizations. Practical and relevant commentary accompanies authoritative reviews of the most recent changes in this complex area of law, creating an essential and comprehensive resource for executives, managers, and other leaders engaged in joint ventures with tax-exempt organizations, as well as the professionals who advise them.

Inhaltsverzeichnis

Preface xiAcknowledgments xiiiChapter 1: Introduction: Joint Ventures Involving Exempt Organizations 11.4 University Joint Ventures 11.5 Low-Income Housing and New Markets Tax Credit Joint Ventures 11.6 Conservation Joint Ventures 21.8 Rev. Rul. 98-15 and Joint Venture Structure 21.10 Ancillary Joint Ventures: Rev. Rul. 2004-51 21.14 The Exempt Organization as a Lender or Ground Lessor 21.15 Partnership Taxation 31.17 Use of a Subsidiary as a Participant in a Joint Venture 31.22 Limitation on Private Foundation's Activities That Limit Excess Business Holdings 31.24 Other Developments (Revised) 4Chapter 2: Taxation of Charitable Organizations 92.1 Introduction 92.2 Categories of Exempt Organizations (Revised) 152.3 501(c)(3) Organizations: Statutory Requirements (Revised) 192.4 Charitable Organizations: General Requirements 222.6 Application for Exemption (Revised) 232.7 Governance 312.8 Form 990: Reporting and Disclosure Requirements (Revised) 322.10 The IRS Audit (Revised) 342.11 Charitable Contributions (Revised) 38Chapter 3: Taxation of Partnerships and Joint Ventures 473.1 Scope of Chapter 473.3 Classification as a Partnership 503.4 Alternatives to Partnerships 503.7 Formation of Partnership 503.8 Tax Basis in Partnership Interest 503.9 Partnership Operations 513.10 Partnership Distributions to Partners (New) 523.11 Sale or Other Disposition of Assets or Interests 523.12 Other Tax Issues 53Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 594.1 Introduction 594.2 Exempt Organization as General Partner: A Historical Perspective 604.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures 624.9 Conversions from Exempt to For-Profit and from For-Profit to Exempt Entities 624.10 Analysis of a Virtual Joint Venture 62Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 655.1 What Are Private Inurement and Private Benefit? 655.2 Transactions in Which Private Benefit or Inurement May Occur 675.3 Profit-Making Activities as Indicia of Nonexempt Purpose 695.4 Intermediate Sanctions (Revised) 695.7 State Activity with Respect to Insider Transactions 78Chapter 6: Engaging in a Joint Venture: The Choices 816.1 Introduction 816.2 LLCs 826.3 Use of a For-Profit Subsidiary as Participant in a Joint Venture (Revised) 836.5 Private Foundations and Program-Related Investments 946.6 Nonprofits and Bonds 986.7 Exploring Alternative Structures 1016.8 Other Approaches (Revised) 102Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 1117.2 Prevention of Abusive Tax Shelters 1117.3 Excise Taxes and Penalties 112Chapter 8: The Unrelated Business Income Tax 1138.1 Introduction 1138.3 General Rule 1148.4 Statutory Exceptions to UBIT 1158.5 Modifications to UBIT 1168.7 Calculation of UBIT (Revised) 116Chapter 9: Debt-Financed Income 1339.1 Introduction 1339.2 Debt-Financed Property 1339.6 The Final Regulations 134Chapter 10: Limitation on Excess Business Holdings 13710.1 Introduction 13710.2 Excess Business Holdings: General Rules 13710.3 Tax Imposed 13910.4 Exclusions (Revised) 139Chapter 12: Healthcare Entities in Joint Ventures 14512.1 Overview 14512.2 Classifications of Joint Ventures 14612.3 Tax Analysis 14712.4 Other Healthcare Industry Issues 14912.5 Preserving the 50/50 Joint Venture 15012.9 Government Scrutiny 15012.11 The Patient Protection and Affordable Care Act of 2010: 501(R)and Other Statutory Changes Impacting Nonprofit Hospitals 15112.12 The Patient Protection and Affordable Care Act of 2010: ACOs and Co-Ops: New Joint Venture Healthcare Entities 154Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 15513.2 Nonprofit-Sponsored LIHTC Project 15513.3 Low-Income Housing Tax Credit (Revised) 15613.4 Historic Investment Tax Credit 15913.6 New Markets Tax Credits (Revised) 16913.10 The Energy Tax Credits 18513.11 The Opportunity Zone Funds: New Section 1400Z-1 and Section 1400Z-2 (Revised) 186Appendix 13B 242Chapter 14: Joint Ventures with Universities 25914.1 Introduction (Revised) 25914.3 Colleges and Universities IRS Compliance Initiative 26514.5 Faculty Participation in Research Joint Ventures 26614.6 Nonresearch Joint Venture Arrangements 26914.7 Modes of Participation by Universities in Joint Ventures 269Chapter 15: Business Leagues Engaged in Joint Ventures 27515.1 Overview 27515.2 The Five-Prong Test 27615.3 Unrelated Business Income Tax 276Chapter 16: Conservation Organizations in Joint Ventures 27716.1 Overview 27716.2 Conservation and Environmental Protection as a Charitable or Educational Purpose: Public and Private Benefit 27716.3 Conservation Gifts and 170(h) Contributions (Revised) 27816.7 Emerging Issues 302Chapter 17: International Joint Ventures 30317.5 General Grantmaking Rules (Revised) 30317.11 Application of Foreign Tax Treaties 305Chapter 19: Debt Restructuring and Asset Protection Issues 30719.1 Introduction 30719.2 Overview of Bankruptcy 30719.3 The Estate and the Automatic Stay 30819.4 Case Administration 30919.5 Chapter 11 Plan 31019.6 Discharge 31119.7 Special Issues: Consequences of Debt Reduction 311Index 313

Über den Autor / die Autorin

MICHAEL I. SANDERS is the lead partner of Blank Rome's Washington office's tax group with a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit transactions. He is also an adjunct professor at The George Washington University Law School and Georgetown University Law Center. He was recently honored in 2010 by The George Washington University Law School for his 35 years of teaching.

Zusammenfassung

Stay up to date on all relevant regulatory and legislative changes, as well as leading case law, in a complicated area of law In the 2021 Cumulative Supplement to the 4th edition of Joint Ventures Involving Tax-Exempt Organizations, a renowned team of authors delivers the latest updates and developments in the legislation, regulations, and case law governing joint ventures with tax-exempt organizations. Practical and relevant commentary accompanies authoritative reviews of the most recent changes in this complex area of law, creating an essential and comprehensive resource for executives, managers, and other leaders engaged in joint ventures with tax-exempt organizations, as well as the professionals who advise them.

Produktdetails

• Autoren: MI Sanders, Michael I Sanders, Michael I. Sanders
• Verlag: Wiley, John and Sons Ltd
• Sprache: Englisch
• Produktform: Taschenbuch
• Erschienen: 31.12.2021
• EAN: 9781119845607
• ISBN: 978-1-119-84560-7
• Seiten: 352
• Themen: Sozialwissenschaften, Recht,Wirtschaft > Wirtschaft > Betriebswirtschaft; Business & management, Gemeinnützige Organisation, Wirtschaft u. Management, Gemeinnützige Organisationen / Management u. Führung, Non-Profit Organizations / Management Leadership