Muutke küpsiste eelistusi

Joint Ventures Involving Tax-Exempt Organizations, 2017 Cumulative Supplement: 2017 Cumulative Supplement 4th edition [Pehme köide]

(The George Washington University Law School; Georgetown University Law Center)
  • Formaat: Paperback / softback, 160 pages, kõrgus x laius x paksus: 252x175x15 mm, kaal: 249 g
  • Ilmumisaeg: 19-Dec-2017
  • Kirjastus: John Wiley & Sons Inc
  • ISBN-10: 1119410185
  • ISBN-13: 9781119410188
Teised raamatud teemal:
  • Pehme köide
  • Hind: 165,25 €*
  • * saadame teile pakkumise kasutatud raamatule, mille hind võib erineda kodulehel olevast hinnast
  • See raamat on trükist otsas, kuid me saadame teile pakkumise kasutatud raamatule.
  • Kogus:
  • Lisa ostukorvi
  • Tasuta tarne
  • Lisa soovinimekirja
Joint Ventures Involving Tax-Exempt Organizations, 2017 Cumulative Supplement: 2017 Cumulative Supplement 4th editionSuurem pilt
  • Formaat: Paperback / softback, 160 pages, kõrgus x laius x paksus: 252x175x15 mm, kaal: 249 g
  • Ilmumisaeg: 19-Dec-2017
  • Kirjastus: John Wiley & Sons Inc
  • ISBN-10: 1119410185
  • ISBN-13: 9781119410188
Teised raamatud teemal:
Püsilink: https://www.kriso.ee/db/9781119410188.html
The definitive guide to compliance for nonprofit joint ventures

Joint Ventures Involving Tax-Exempt Organizations explores the laws, rules, and policies surrounding increasing collaborations between the nonprofit and for-profit sectors. Comprehensive, authoritative, and focused on the practical, this resource has been fully updated to reflect the latest rulings and regulatory changes pertaining to tax-exempt organizations. Countless footnotes, numerous citations to case law, Internal Revenue Code sections, and other relevant authority are provided, along with a host of useful sample forms.

In an era of challenging economic forces, budgetary constraints and potential tax legislation, nonprofits and for-profits are partnering in creative arrangements to achieve mutual financial and tax-exempt goals. Improper structuring and inadequate safeguards can jeopardize an organization's tax-exempt status; careful planning is critical. Thorough examination of relevant laws and rulings guides practitioners and participants so that both the non-profit and for-profit partners will understand the requirements for maintaining tax-exemption:

  • Analyze the various joint venture configurations that will protect tax-exempt status, including the new partnership audit rules
  • Propose solutions to common challenges such as debt restructuring, use of tax credit financing, and asset protection issues
  • Identify the structures best suited to achieve various goals based on applicable legal factors

Partnering with for-profit businesses has brought both successes and unforeseen challenges to universities, research institutions, hospitals, low-income housing developments, and many more. As the charitable funding environment continues to face stresses, alternative avenues to generate revenue, such as joint ventures, will only become more prevalent. Joint Ventures Involving Tax-Exempt Organizations provides an invaluable resource for lawyers and nonprofits alike, putting the critical information you need at your fingertips.

Preface xi
Acknowledgments xiv
Chapter 1 Introduction: Joint Ventures Involving Exempt Organizations
1(4)
§ 1.4 University Joint Ventures
1(1)
§ 1.5 Low-Income Housing and New Markets Tax Credit Joint Ventures (Revised)
1(1)
§ 1.6 Conservation Joint Ventures
2(1)
§ 1.10 Ancillary Joint Ventures: Rev. Rul. 2004-51
2(1)
§ 1.14 The Exempt Organization as a Lender or Ground Lessor
2(1)
§ 1.15 Partnership Taxation (Revised)
3(1)
§ 1.17 Use of a Subsidiary as a Participant in a Joint Venture
3(1)
§ 1.22 Limitation on Private Foundation's Activities That Limit Excess Business Holdings (New)
3(1)
§ 1.24 Other Developments
4(1)
Chapter 2 Taxation of Charitable Organizations
5(20)
§ 2.1 Introduction
5(1)
§ 2.2 Categories of Exempt Organizations
5(1)
§ 2.3 §501(c)(3) Organizations: Statutory Requirements (Revised)
5(1)
§ 2.6 Application for Exemption (Revised)
6(6)
§ 2.7 Governance (Revised)
12(1)
§ 2.8 Form 990: Reporting and Disclosure Requirements
13(1)
§ 2.10 The IRS Audit (New)
14(3)
§ 2.11 Charitable Contributions (Revised)
17(8)
Chapter 3 Taxation of Partnerships and Joint Ventures
25(6)
§ 3.3 Classification as a Partnership
25(1)
§ 3.4 Alternatives to Partnerships
25(1)
§ 3.8 Tax Basis in Partnership Interest
26(1)
§ 3.9 Partnership Operations
26(1)
§ 3.11 Sale or Other Disposition of Assets or Interests (Revised)
27(1)
§ 3.12 Other Tax Issues (Revised)
27(4)
Chapter 4 Overview: Joint Ventures Involving Exempt Organizations
31(4)
§ 4.2 Exempt Organization as General Partner: A Historical Perspective
31(1)
§ 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures (New)
32(1)
§ 4.9 Conversions from Exempt to For-Profit and from For-Profit to Exempt Entities (New)
32(1)
§ 4.10 Analysis of a Virtual Joint Venture
33(2)
Chapter 5 Private Benefit, Private Inurement, and Excess Benefit Transactions
35(6)
§ 5.1 What Are Private Inurement and Private Benefit? (Revised)
35(1)
§ 5.2 Transactions in Which Private Benefit or Inurement May Occur
36(1)
§ 5.3 Profit-Making Activities as Indicia of Nonexempt Purpose
37(1)
§ 5.4 Intermediate Sanctions (Revised)
37(1)
§ 5.7 State Activity with Respect to Insider Transactions
38(3)
Chapter 6 Engaging in a Joint Venture: The Choices
41(14)
§ 6.2 LLCs
41(1)
§ 6.3 Use of a For-Profit Subsidiary as Participant in a Joint Venture (Revised)
41(4)
§ 6.5 Private Foundations and Program-Related Investments (Revised)
45(5)
§ 6.6 Nonprofits and Bonds
50(2)
§ 6.7 Exploring Alternative Structures
52(1)
§ 6.8 Other Approaches (Revised)
52(3)
Chapter 7 Exempt Organizations as Accommodating Parties in Tax Shelter Transactions
55(2)
§ 7.2 Prevention of Abusive Tax Shelters (Revised)
55(1)
§ 7.3 Excise Taxes and Penalties
56(1)
Chapter 8 The Unrelated Business Income Tax
57(2)
§ 8.1 Introduction
57(1)
§ 8.3 General Rule (Revised)
58(1)
Chapter 9 Debt-Financed Income
59(4)
§ 9.1 Introduction
59(1)
§ 9.2 Debt-Financed Property
59(1)
§ 9.6 The Final Regulations (New)
59(4)
Chapter 10 Limitation on Excess Business Holdings
63(4)
§ 10.1 Introduction
63(1)
§ 10.2 Excess Business Holdings: General Rules (Revised)
63(1)
§ 10.3 Tax Imposed
63(1)
§ 10.4 Exclusions (Revised)
63(4)
Chapter 12 Healthcare Entities in Joint Ventures
67(8)
§ 12.2 Classifications of Joint Ventures
67(1)
§ 12.3 Tax Analysis
67(1)
§ 12.4 Other Healthcare Industry Issues
68(1)
§ 12.5 Preserving the 50/50 Joint Venture
68(1)
§ 12.9 Government Scrutiny
69(1)
§ 12.11 The Patient Protection and Affordable Care Act of 2010: §501(r) and Other Statutory Changes Impacting Nonprofit Hospitals
69(3)
§ 12.12 The Patient Protection and Affordable Care Act of 2010: ACOs and Co-Ops: New Joint Venture Healthcare Entities
72(3)
Chapter 13 Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs
75(22)
§ 13.3 Low-Income Housing Tax Credit
75(1)
§ 13.4 Historic Investment Tax Credit
76(4)
§ 13.6 New Markets Tax Credits (Revised)
80(14)
§ 13.10 The Energy Tax Credits (Revised)
94(3)
Chapter 14 Joint Ventures with Universities
97(4)
§ 14.5 Faculty Participation in Research Joint Ventures
97(1)
§ 14.6 Nonresearch Joint Venture Arrangements
97(1)
§ 14.7 Modes of Participation by Universities in Joint Ventures
98(3)
Chapter 15 Business Leagues Engaged in Joint Ventures
101(2)
§ 15.1 Overview
101(1)
§ 15.2 The Five-Prong Test
102(1)
§ 15.3 Unrelated Business Income Tax
102(1)
Chapter 16 Conservation Organizations in Joint Ventures
103(14)
§ 16.1 Overview
103(1)
§ 16.2 Conservation and Environmental Protection as a Charitable or Educational Purpose: Public and Private Benefit
103(1)
§ 16.3 Conservation Gifts and §170(h) Contributions (Revised)
104(10)
§ 16.7 Emerging Issues
114(3)
Chapter 17 International Joint Ventures
117(4)
§ 17.5 General Grantmaking Rules (New)
117(1)
§ 17.11 Application of Foreign Tax Treaties (Revised)
118(3)
Chapter 19 Debt Restructuring and Asset Protection Issues
121(4)
§ 19.2 Overview of Bankruptcy (Revised)
121(1)
§ 19.3 The Estate and the Automatic Stay (Revised)
121(1)
§ 19.4 Case Administration (New)
122(1)
§ 19.5
Chapter 11 Plan (Revised)
122(3)
Index 125
MICHAEL I. SANDERS (Washington DC) 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. Sanders is also an adjunct professor at George Washington University Law Center and Georgetown University Law School teaching Income Taxation of Partnerships and Subchapter S Corporations and Tax Treatment of Charities and Other Non-Profit Organizations, Joint Ventures Involving Tax Exempt Organizations (including healthcare, universities, LIHTC, new markets, conservation organizations, respectively. Previously, Mr. Sanders served as an attorney-advisor to the assistant secretary of tax policy at the Office of Tax Legislative Counsel and as a trial attorney at the U.S. Department of Justice (Attorney General's Honors Program). He was recently honored in 2010 by The George Washington University School of Law for his 35 years of teaching at the law school.