Joint ventures involving tax-exempt organizations
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Joint ventures involving tax-exempt organizations
J. Wiley & Sons, c2010
3rd ed,. 2010 cumulative suppl
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Includes bibliographical references and index
内容説明・目次
内容説明
This comprehensive, revised, and expanded guide covers tax-exempt organizations and joint ventures and includes sample forms, countless footnotes, and numerous citations to case law, Internal Revenue Code sections, and other relevant rulings. Covering international joint ventures and anti-terrorism laws and continued treatment on the application of Sarbanes-Oxley-like laws in the nonprofit sector, Joint Ventures Involving Tax-Exempt Organizations, Third Edition includes the latest case law, treasury regulations, and IRS rulings to enable nonprofits to maximize their financing without jeopardizing their tax-exempt status.
目次
Note to the Reader: Sections not in the main bound volume, Joint Ventures Involving Tax-Exempt Organizations Third Edition (978-0470-03761-4) are indicated by "(New)" after the title. Material from the main bound volume that has been updated for this supplement is indicated by "(Revised)" after the title. Acknowledgments. Preface. Chapter One: Introduction: Joint Ventures Involving Exempt Organizations Generally. 1.2 Joint Ventures in General. 1.3 Healthcare Joint Ventures. 1.4 University Joint Ventures. 1.5 Low-Income Housing Joint Ventures. 1.20 "Intangibles" Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture. 1.24 Other Developments. Chapter Two: Taxation of Charitable Organizations. 2.3 Section 501(c) Organizations: Structural Elements. 2.4 Statutory Requirements. 2.8 Application for Exemption. 2.9 Reporting Requirements. 2.9A Redesigned 2008 Form 990 (New). 2.13A Focus on Good Governance (New). Appendix 2A: Redesigned Form 990 (2008). Chapter Three: Taxation of Partnerships and Joint Ventures. 3.1 Scope of Chapter. 3.2 Qualifying As A Partnership. 3.6 Allocation of Profits, Losses, and Credits. 3.9 Partnership Operations. 3.12 Other Tax Issues. Chapter Four: Overview: Joint Ventures Involving Exempt Organizations. 4.2 Exempt Organization As General Partner: A Historical Perspective. 4.4 Joint Ventures with other Exempt Organizations. 4.5 New Scheme for Analyzing Joint Ventures. 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures. 4.8 Use of a Subsidiary as Participant in a Joint Venture. 4.8A Social Entrepreneurs: Operating Without Exemption (New). 4.9 Use of a Supporting Organization in a Joint Venture. 4.14 Reporting Requirements. Appendix 4A: Joint Venture Checklist (Revised). Appendix 4B: Redesigned Form 990 (2008) New Schedule R, Related Organizations and Unrelated Partnerships (New). Appendix 4C: Model Joint Venture Participation Policy (New). Chapter Five: Private Benefit, Private Inurement, and Excess Benefit Transactions. 5.1 What Are Private Inurement and Private Benefit? 5.2 Transactions in which Private Benefit or Inurement May Occur. 5.4 Intermediate Sanctions. Chapter Seven: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions. 7.2 Prevention of Abusive Tax Shelters. 7.3 Excise Taxes and Penalties. Chapter Eight: The Unrelated Business Income Tax. 8.1 Introduction. 8.3 General Rule. 8.4 Statutory Exceptions to UBIT. 8.5 Modifications to UBIT. 8.8 Governmental Scrutiny and Legislative Initiatives. Chapter Nine: Debt-Financed Income. 9.2 Debt-Financed Property. Chapter Ten: Limitation on Excess Business Holdings. 10.1 Introduction. 10.2 Excess Business Holdings: General Rules. Chapter Eleven: Impact on Taxable Joint Ventures: Tax-exempt Entity Leasing Rules. 11.5 Restrictions on Tax-Exempt Use Property. Chapter Twelve: Healthcare Entities in Joint Ventures. 12.3 Tax Analysis. 12.4 Other Healthcare Industry Issues. 12.7 Joint Operating Agreements. 12.8 UBIT Implications of Hospital Joint Ventures. 12.9 Government Scrutiny. Appendix 12B: Redesigned Form 990 (2008) Schedule H, Hospitals (New). Appendix 12C: Model Joint Venture Participation Policy (New). Chapter Thirteen: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs. 13.2 Low-Income Housing Tax Credit. 13.3 Historic Investment Tax Credit. 13.5 New Market Tax Credits. 13.6 Recent IRS Guidance Regarding Guarantees and Indemnifications. 13.8 Gulf Zone Opportunity Act of 2005. Appendix 13A: New Markets Tax Credits Project Compliance/Qualifications/Accounting Projections Checklist (Revised). Chapter Fourteen: Joint Ventures with Universities. 14.2 IRS Focus on Universities. 14.7 Modes of Participation by Universities in Joint Ventures. Chapter Fifteen: Business Leagues Engaged in Joint Ventures. 15.2 The Five Prong Test. Chapter Sixteen: Conservation Organizations in Joint Ventures. 16.3 Conservation Gifts and 170(h) Contributions. 16.7 Emerging Issues. Chapter Seventeen: International Joint Ventures. 17.1 Overview. 17.3 Potential for Abuse: The Use of Charities as Accommodating Parties in International Terrorist Activities. 17.4 Guidelines for U.S.-Based Charities Engaging in International AID and International Charities. 17.12 Current Developments In Cross-Border Charitable Activities. Appendix 17A: Redesigned Form 990 (2008) New Schedule F, Statement of Activities Outside the United States (New). Chapter Eighteen: Private Pension Fund Investments in Joint Ventures. 18.1 Overview. 18.2 Private Pension Fund Participation in Joint Ventures. Chapter Nineteen: Exempt Organizations Investing through Limited Liability Companies. 19.2 The Basics of LLCs: State and Federal Income Tax Law. 19.3 Comparison with Other Business Entities. 19.5 Tax Classification of LLCs Under Check-the-Box Regulations. 19.6 Exempt Organizations Wholly Owning Other Entities. 19.7 IRS Analysis: The Double-Prong Test and Rev. Rul. 95-15. 19.8 Nonprofit-Sponsored LIHTC Project. 19.9 Private Foundations as Members of LLCs. Chapter Twenty: Debt Restructuring and Asset Protection Issues. 20.1 Introduction. 20.2 Overview of Bankruptcy. 20.3 Automatic Stay. 20.4 Chapter 11 Plan of Reorganization. 20.5 Discharge. Index.
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