A comprehensive, revised and expanded guide for tax-exempt organizations involved in joint ventures. Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition examines the liability and consequences of exemption for organizations involved in for-profit joint ventures and other tax-exempt organizations. This authoritative guide provides unhindered access to relevant IRC regulations, financial regulations, IRS decisions and relevant court decisions and legislative developments affecting tax-exempt organizations involved in joint ventures.
Provides an in-depth analysis of IRS requirements for structuring joint ventures to protect a nonprofit's exemption and minimize UBIT
Includes sample templates, checklists, and numerous citations for sections of the Internal Revenue Code, Treasury Regulations, case law, and IRS rulings
Presents templates, guidelines, and suggestions for structuring joint ventures and minimizing audit risk
Includes in-depth coverage of: new Internal Revenue Code requirements impacting nonprofit hospitals, including Section 501(r) and related regulations; University Corporations, Revised Form 990, Focusing on Nonprofit Organizations Involved in Joint Ventures; the IRS's emphasis on good governance practices; international activities of non-profit organizations; and a comprehensive examination of the Novo Mercado Tax Credits and Tax Credits for Affordable Housing area
Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition, written by a recognized expert in the field, is the most thorough discussion of this critical topic.
<b>A comprehensive, revised and expanded guide for tax-exempt organizations involved in joint ventures</b>
<i>Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition</i> examines liability and consequences for tax-exempt organizations involved in for-profit joint ventures and other tax-exempt entities. This authoritative guide provides unhindered access to relevant IRC regulations, financial regulations, IRS decisions and relevant court decisions and legislative developments affecting tax-exempt organizations involved in joint ventures.
<ul><li>Provides an in-depth analysis of IRS requirements for structuring joint ventures to protect a nonprofit's tax exemption and minimize UBIT</li><li>Includes sample templates, verification lists, and numerous section citations of the Internal Revenue Code, Treasury Regulations, case law and IRS decisions</li><li>Presents templates, guidelines and suggestions for structuring joint ventures and minimizing audit risk</li><li>Provides detailed information Coverage of: new Internal Revenue Code requirements affecting nonprofit hospitals, including Section 501(r) and related regulations; University Corporations, Revised Form 990, Focusing on Nonprofit Organizations Involved in Joint Ventures; the IRS's emphasis on good governance practices; international activities of non-profit organizations; and a comprehensive review of the Novo Mercado Tax Credits and Low Income Housing Tax Credits area</li></ul>
Written by a recognized expert in the field, <i>Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition</i> is the most comprehensive discussion of this critical topic.
| Edition: | 4th revised edition |
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| Place of publication: |
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| Publishing group: | John Wiley & Sons Inc. |
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| ISBN-13: | 978-1-119-98538-9 (9781119985389) |
Bibliographic data and cover photos are copyright Nielsen Book Services Limited or the publishers or their respective licensors: all rights reserved.
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Foreword xi
thanks xiv
Chapter 1: Introduction: Joint Ventures with Exempt Organizations 1
? 1.4 University cooperation 1
? 1.5 Low Income
Joint ventures and new markets for housing tax credits 1
? 1.6 Conservation Joint Ventures 2
? 1.8 Rev. The role. 98-15
and joint venture structure 2
? 1.10 Joint Ventures Auxiliares: Rev. Rul. 2004-51
2
? 1.14 The Exempt Organization as a Lender or Lessor of Immovables 2
? 1.15 Taxation of the company 3
? 1.17 Use of a subsidiary as an interest in a joint venture 3
? 1.22 Restricting the activities of private foundations that restrict
Excess commercial interests 4
? 1.24 Other developments 4
Chapter 2: Taxation of non-profit organizations
? 2.1 Introduction 9
? 2.2 Categories of exempt organizations (revised) 15
? 2.3? 501(c)(3) Organizations: Legal Requirements 19
? 2.4 Non-profit organizations: general requirements 22
? 2.5 Categories of non-profit organizations (new) 23
? 2.6 Exemption application 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 donations (revised) 42
Chapter 3: Taxation of companies and joint ventures 53
? 3.1 Scope of Chapter 53
? 3.3 Classification as a company (revised) 56
? 3.4 Alternatives to partnerships 70
? 3.7 Society formation 70
? 3.8 Tax base for shares in the company 70
? 3.9 Partnership Operations 71
? 3.10 Company Distributions to Members 72
? 3.11 Sale or other disposal of assets or interests 72
? 3.12 Other tax issues 73
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Contents
? vii?
Chapter 4: Overview: Joint Ventures with Exempt Organizations 79
? 4.1 Introduction 79
? 4.2 Organization Exempted from General Membership: A Background
perspective 80
? 4.6 Tax Decision 2004-51
from auxiliary joint ventures 82
? 4.9 Profit-Exempt Conversions
and for profit
Exempted entities 82
? 4.10 Analysis of a virtual joint venture 82
5. Kapitel: Private Benefit, Private Benefit und Excess Benefit
Transactions 85
? 5.1 What are private pensions and private benefits? 85
? 5.2 Transactions in which a private benefit or benefit may occur 87
? 5.3 Profit
Activities as indications of non-exempt purposes 89
? 5.4 Intermediate Penalties (revised) 89
? 5.7 State activity in internal transactions 99
Chapter 6: Joining a Joint Venture: The Choices 101
? 6.1 Introduction 101
? 6.2 LLCs 102
? 6.3 Commercial Use
Subsidiary as a partner in a joint venture
(Revised) 103
? 6.5 Private and Program Foundations
investments
(Revised) 115
? 6.6 Non-profit organizations and commitments 120
? 6.7 Exploring alternative frameworks (revised) 122
? 6.8 Other approaches 126
Chapter 7: Liberated Organizations as Accommodating Parties
for tax protection transactions 135
? 7.2 Prevention of abusive tax relief 135
? 7.3 Special excise duties and fines 136
Chapter 8: The Income Tax of Independent Enterprises 137
? 8.1 Introduction 137
? 8.3 General Rule 138
? 8.4 Legal exceptions to UBIT 139
? 8.5 Adjustments to UBIT 140
? 8.7 Calculation UBIT 140
Chapter 9: Debt financed
Income 157
? 9.1 Introduction 157
? 9.2 Debt-Financed
property 157
? 9.3 Exception ?514(c)(9) (New) 158
? 9.6 The Final Order 158
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Contents
? ix?
Chapter 10: Limiting Excess Corporate Interests 161
? 10.1 Introduction 161
? 10.2 Surplus Corporate Interests: General Rules (revised) 161
? 10.3 Tax offset 163
? 10.4 Exclusions (revised) 164
Chapter 11: Impact on Taxable Joint Ventures: Tax Exemption
Lease rules for entities (new) 169
? 11.3 Federal Tax Code? 168(A) 169
Chapter 12: Healthcare Facilities in Joint Ventures 171
? 12.1 Overview 171
? 12.2 Classifications of joint ventures 172
? 12.3 Tax Analysis 173
? 12.4 Other health sector issues 175
? 12.5 Obtaining a joint venture 50/50 176
? 12.9 State Control 176
? 12.11 The Patient Protection and Affordable Care Act 2010:
? 501(R) and Other Legislative Changes Having an Impact
Non-profit hospitals 177
? 12.12 The Patient Protection and Affordable Care Act
2010: ACOs and cooperatives:
Nova-Joint-Venture
Health Facilities (revised) 180
Chapter 13: Low Income
Housing, New Markets, Rehabilitation and
Other tax credit programs 181
? 13.2 Sponsored by Charitable Organizations
LIHTC 181-Project
? 13.3 Low Income
Residential Tax Credit (revised) 182
? 13.4 Historical Investment Tax Credit 186
? 13.6 New Market Tax Credits (revised) 196
? 13.10 Energy Tax Credits 212
? 13.11 Opportunity Zone Floors: New Section 1400Z-1
e
Section 1400Z-2
(Revised) 213
Appendix 13B 275
Chapter 14: Cooperation with universities 291
? 14.1 Introduction 291
? 14.3 Colleges and Universities IRS Compliance Initiative 297
? 14.5 Faculty participation in research collaborations 298
? 14.6 Non-Research Joint Venture Arrangements 301
? 14.7 Forms of University Participation in Joint Ventures
(Revised) 301
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Contents
? X?
Chapter 15: Business Leagues Involved in Joint Ventures 313
? 15.1 Overview 313
? 15.2 The Five Points
Test (revised) 314
? 15.3 Foreign Trade Tax 315
Chapter 16: Conservation Organizations in Joint Ventures 317
? 16.1 Overview 317
? 16.2 Protecting the Environment and Protecting the Environment as a Charity
or educational purpose: public and private benefit 317
? 16.3 Conservation gifts and ? 170(H) Contributions (revised) 318
? 16.7 Emerging Issues 344
Chapter 17: International Joint Ventures 345
? 17.5 General Rules for Donations 345
? 17.11 Application of Foreign Tax Treaties 347
Chapter 19: Debt restructuring and asset protection issues 351
? 19.1 Introduction 351
? 19.2 Bankruptcy summary 351
? 19.3 The station wagon and automatic suspension 352
? 19.4 Fallmanagement 353
? 19.5 Chapter 11 Blueprint 354
? 19.6 Liberation 355
? 19.7 Special topics: Consequences of debt reduction 355
Index 000
Swiss classification
- Business
administration / business administration- to the industry
- The nonprofit organization
- Business
- administration / business administration
- Management
- guide
rating theme
- Economics, Finance, Business Administration and Management
- business and administration
- entrepreneurship and organization
- Charities (Nonprofit)
- Economics, Finance, Business Administration and Management
- business and administration
- management techniques and management
DNB DDC topic groups
- Management
- Social Sciences, Sociology, Anthropology
- Business
BIC 2 rating
- nonprofit organizations
BISAC-Rating
Product group system 2.0
- Social Sciences, Law, Economics
- Business
- Business Administration
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