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Klappentext Insightful analysis and explanations of private foundation tax law along with hands-on practice tools that make compliance easier Now in its seventh edition, The Tax Law of Private Foundations by Bruce Hopkins and Shane Hamilton serves as the gold-standard reference for navigating the complex regulations governing private foundations. This comprehensive book is regularly updated to incorporate the latest changes in tax law, providing executives and professionals with valuable clarification, expert insights, and practical instruction. With every edition supplemented annually, the book remains current and relevant. It offers a clear and concise summary of the regulations governing private foundations, explaining the logic underpinning the rules. The authors provide a range of helpful tools, including checklists, sample documents, and practice forms, to simplify the filing process and ensure compliance with the latest legislation. Readers will also find: Critical analyses and considerations of existing laws and regulations, avoiding potential confusion arising from future legislation A collection of practical tools that make it simpler to comply with the regulations governing private foundations Expert guidance on obtaining or maintaining your foundation's tax-exempt status An indispensable resource, this latest edition caters to individuals with personal or professional interests in private foundations, offering authoritative guidance and complete explanations in an intricate and sometimes confusing area of the law. Whether navigating the complexities of compliance or seeking deep insights, this book remains the go-to reference for understanding and managing this difficult area of taxation. Inhaltsverzeichnis Preface xiii Book Citations xvii 1 Introduction to Private Foundations 1 1.1 Private Foundations: Unique Organizations 1 1.2 Definition of Private Foundation 2 1.4 Private Foundation Law Primer 2 (c) Disqualified Persons 2 (f) Excess Business Holdings Rules 2 (l) Unrelated Business Rules 2 1.7 Organizational Rules 2 1.8 Private Foundation Law Sanctions 3 (b) Self- Dealing Sanctions as Pigouvian Taxes 3 (c) Self- Dealing Sanctions: Taxes or Penalties? 4 (e) Potential of Overlapping Taxes 5 1.9 Statistical Profile 5 1.10 Private Foundations and Law 50 Years Later 5 2 Starting, Funding, and Governing a Private Foundation 7 2.3 Choice of Organizational Form 7 2.4 Funding a Foundation 7 2.6 Foundations and Planned Giving 8 (b) Charitable Remainder Trusts 8 (d) Interrelationships with Private Foundation Rules 8 2.7 Acquiring Recognition of Tax- Exempt Status 9 (a) Form 1023 9 (b) 27- Month Rule 9 (c) IRS Determination Letters Recognizing Exempt Status 10 (d) Administrative Procedures When Recognition Denied 10 (e) Declaratory Judgment Procedures When Recognition Denied 11 (f) Recognition of Foreign Organizations 11 3 Types of Private Foundations 13 3.1 Private Operating Foundations 13 (d) Income Test 13 (h) Conversion to or from Private Operating Foundation Status 13 3.2 Exempt Operating Foundations 14 3.3 Conduit Foundations 15 3.6 Nonexempt Charitable Trusts 16 3.7 Split- Interest Trusts 17 3.8 Foreign Private Foundations 19 (a) Gross Investment Income Tax 19 (b) Withholding Tax 20 (c) 85 Percent Support Test 21 (d) Return Filing Obligations 21 (e) Establishing Public Charity Status 21 (f) Loss of Exemption (Prohibited Transactions) 22 4 Disqualified Persons 23 4.5 Corporations or Partnerships 23 4.7 Private Foundations 23 4.8 Governmental Officials 24 4.9 Termination of Disqualified Person Status ...
