Fr. 190.00

Sanders, MI Sanders, Michael I Sanders, Michael I. Sanders, Michael I. (The George Washington Univers Sanders, Sanders Michael I.

Joint Ventures Involving Tax Exempt Organizations, 2022 Cumulative - Supplemen

English · Paperback / Softback

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Description

A comprehensive, revised, and expanded guide covering tax-exempt organizations engaging in joint ventures

Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition examines the liability of, and consequences to, exempt organizations participating in joint ventures with for-profit and other tax-exempt entities. This authoritative guide provides unbridled access to relevant IRC provisions, Treasury regulations, IRS rulings, and pertinent judicial decisions and legislative developments that impact exempt organizations involved in joint ventures.
* Features in depth analysis of the IRS's requirements for structuring joint ventures to protect a nonprofit's exemption as well as to minimize UBIT
* Includes sample models, checklists, and numerous citations to Internal Revenue Code sections, Treasury Regulations, case law, and IRS rulings
* Presents models, guidelines, and suggestions for structuring joint ventures and minimizing the risk of audit
* Contains detailed coverage of: new Internal Revenue Code requirements impacting charitable hospitals including Section 501(r) and related provisions; university ventures, revised Form 990, with a focus on nonprofits engaged in joint ventures; the IRS's emphasis on good governance practices; international activities by nonprofits; and a comprehensive examination of the New Market Tax Credits and Low Income Housing Tax Credits arena

Written by a noted expert in the field, Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition is the most in-depth discussion of this critical topic.

List of contents

Preface xi

Acknowledgments xv

Chapter 1: Introduction: Joint Ventures Involving Exempt Organizations 1

1.4 University Joint Ventures 1

1.5 Low- Income Housing and New Markets Tax Credit Joint Ventures 1

1.6 Conservation Joint Ventures 2

1.8 Rev. Rul. 98- 15 and Joint Venture Structure 2

1.10 Ancillary Joint Ventures: Rev. Rul. 2004- 51 2

1.14 The Exempt Organization as a Lender or Ground Lessor 2

1.15 Partnership Taxation 3

1.17 Use of a Subsidiary as a Participant in a Joint Venture 3

1.22 Limitation on Private Foundation's Activities That Limit Excess Business Holdings 4

1.24 Other Developments 4

Chapter 2: Taxation of Charitable Organizations 9

2.1 Introduction 9

2.2 Categories of Exempt Organizations (Revised) 15

2.3 501(c) (3) Organizations: Statutory Requirements 19

2.4 Charitable Organizations: General Requirements 22

2.5 Categories of Charitable Organizations (New) 23

2.6 Application for Exemption 25

2.7 Governance 34

2.8 Form 990: Reporting and Disclosure Requirements (Revised) 35

2.9 Redesigned Form 990 (New) 37

2.10 The IRS Audit (Revised) 37

2.11 Charitable Contributions (Revised) 42

Chapter 3: Taxation of Partnerships and Joint Ventures 53

3.1 Scope of Chapter 53

3.3 Classification as a Partnership (Revised) 56

3.4 Alternatives to Partnerships 70

3.7 Formation of Partnership 70

3.8 Tax Basis in Partnership Interest 70

3.9 Partnership Operations 71

3.10 Partnership Distributions to Partners 72

3.11 Sale or Other Disposition of Assets or Interests 72

3.12 Other Tax Issues 73

Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 79

4.1 Introduction 79

4.2 Exempt Organization as General Partner: A Historical Perspective 80

4.6 Revenue Ruling 2004- 51 and Ancillary Joint Ventures 82

4.9 Conversions from Exempt to For- Profit and from For- Profit to Exempt Entities 82

4.10 Analysis of a Virtual Joint Venture 82

Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 85

5.1 What Are Private Inurement and Private Benefit? 85

5.2 Transactions in Which Private Benefit or Inurement May Occur 87

5.3 Profit- Making Activities as Indicia of Nonexempt Purpose 89

5.4 Intermediate Sanctions (Revised) 89

5.7 State Activity with Respect to Insider Transactions 99

Chapter 6: Engaging in a Joint Venture: The Choices 101

6.1 Introduction 101

6.2 LLCs 102

6.3 Use of a For- Profit Subsidiary as Participant in a Joint Venture (Revised) 103

6.5 Private Foundations and Program- Related Investments (Revised) 115

6.6 Nonprofits and Bonds 120

6.7 Exploring Alternative Structures (Revised) 122

6.8 Other Approaches 126

Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 135

7.2 Prevention of Abusive Tax Shelters 135

7.3 Excise Taxes and Penalties 136

Chapter 8: The Unrelated Business Income Tax 137

8.1 Introduction 137

8.3 General Rule 138

8.4 Statutory Exceptions to UBIT 139

8.5 Modifications to UBIT 140

8.7 Calculation of UBIT 140

Chapter 9: Debt- Financed Income 157

9.1 Introduction 157

9.2 Debt- Financed Property 157

9.3 The 514(c) (9) Exception (New) 158

9.6 The Final Regulations 158

Chapter 1

Summary

Product details

Authors	Sanders, MI Sanders, Michael I Sanders, Michael I. Sanders, Michael I. (The George Washington Univers Sanders, Sanders Michael I.
Publisher	Wiley, John and Sons Ltd

Languages	English
Product format	Paperback / Softback
Released	28.02.2023

EAN	9781119985204
ISBN	978-1-119-98520-4
No. of pages	400
Subjects	Social sciences, law, business > Business > Management Business & management, Gemeinnützige Organisation, Wirtschaft u. Management, Gemeinnützige Organisationen / Management u. Führung, Non-Profit Organizations / Management Leadership

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