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Joint Ventures Involving Tax-Exempt Organizations: 2012 Cumulative Supplement, 3rd EditionISBN: 978-1-118-03752-2
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400 pages
April 2012, ©2012
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Acknowledgments xiii
Preface xv
Chapter One: Introduction: Joint Ventures Involving Exempt Organizations Generally 1
§ 1.2 Joint Ventures in General 1
§ 1.3 Healthcare Joint Ventures 1
§ 1.4 University Joint Ventures 2
§ 1.5 Low-Income Housing Joint Ventures 2
§ 1.20 "Intangibles" Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture 2
§ 1.24 Other Developments 2
Chapter Two: Taxation of Charitable Organizations 3
§ 2.3 Section 501(c) Organizations: Structural Elements 3
§ 2.4 Statutory Requirements 3
§ 2.8 Application for Exemption 12
§ 2.9 Reporting Requirements 14
§ 2.9A Redesigned Form 990 (New) 16
§ 2.13A Focus on Good Governance (New) 56
Appendix 2A: Redesigned Form 990 (2010) (New) 61
Chapter Three: Taxation of Partnerships and Joint Ventures 75
§ 3.1 Scope of Chapter 75
§ 3.2 Qualifying as a Partnership 75
§ 3.6 Allocation of Profits, Losses, and Credits 75
§ 3.7 Formation of Partnership 76
§ 3.8 Tax Basis in Partnership Interests 77
§ 3.9 Partnership Operations 77
§ 3.12 Other Tax Issues 78
Chapter Four: Overview: Joint Ventures Involving Exempt Organizations 81
§ 4.2 Exempt Organization as a General Partner: A Historical Perspective 81
§ 4.4 Joint Ventures with Other Exempt Organizations 83
§ 4.5 New Scheme for Analyzing Joint Ventures 83
§ 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures 84
§ 4.8 Use of a Subsidiary as Participant in a Joint Venture 86
§ 4.8A Social Entrepreneurs: Exploring Alternative Structures (New) 92
§ 4.9 Use of a Supporting Organization in a Joint Venture 98
§ 4.12 Exempt Organization as Lender or Ground Lessor 103
§ 4.14 Reporting Requirements 104
Appendix 4A: Joint Venture Checklist (Revised) 109
Appendix 4B: Redesigned Form 990 (2010 Schedule R, Related Organizations and Unrelated Partnerships) (New) 115
Appendix 4C: Model Joint Venture Participation Policy (New) 121
Chapter Five: Private Benefit, Private Inurement, and Excess Benefit Transactions 125
§ 5.1 What Are Private Inurement and Private Benefit? 125
§ 5.2 Transactions in Which Private Benefit or Inurement May Occur 126
§ 5.4 Intermediate Sanctions 129
§ 5.6 Planning 133
Chapter Six: The Exempt Organization as Lender or Ground Lessor 135
§ 6.1 Overview 135
§ 6.4 Participating Loans 135
§ 6.5 Ground Lease with Leasehold Mortgage 135
§ 6.6 Sale of Undeveloped Land 136
§ 6.7 Guarantees 136
Chapter Seven: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 137
§ 7.2 Prevention of Abusive Tax Shelters 137
§ 7.3 Excise Taxes and Penalties 140
Chapter Eight: The Unrelated Business Income Tax 143
§ 8.1 Introduction 143
§ 8.3 General Rule 144
§ 8.4 Statutory Exceptions to UBIT 145
§ 8.5 Modifications to UBIT 145
§ 8.7 Calculation of UBIT 147
§ 8.8 Governmental Scrutiny and Legislative Initiatives 147
Chapter Nine: Debt-Financed Income 151
§ 9.1 Introduction 151
§ 9.2 Debt-Financed Property 151
§ 9.3 The §514(c)(9) Exception 152
Chapter Ten: Limitation on Excess Business Holdings 153
§ 10.1 Introduction 153
§ 10.2 Excess Business Holdings: General Rules 153
§ 10.4 Exclusions 154
Chapter Eleven: Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules 155
§ 11.3 Internal Revenue Code §168(h) 155
§ 11.5 Restrictions on Tax-Exempt Use Property 155
Chapter Twelve: Healthcare Entities in Joint Ventures 159
§ 12.3 Tax Analysis 159
§ 12.4 Other Healthcare Industry Issues 162
§ 12.7 Joint Operating Agreements 170
§ 12.8 UBIT Implications of Hospital Joint Ventures 170
§ 12.9 Government Scrutiny 171
§ 12.9A The Patient Protection and Affordable Care Act of 2010: §501(r) and Other Statutory Changes Impacting Nonprofit Hospitals (New) 178
§ 12.9B The Patient Protection and Affordable Care Act of 2010: ACOs and CO-OPs: New Joint Venture Health Care Entities (New) 200
Appendix 12B: Redesigned Form 990 (2010), Schedule H, Hospitals (New) 213
Appendix 12C: Model Joint Venture Participation Policy (New) 222
Chapter Thirteen: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 227
§ 13.1 Relationships between Nonprofits and For-Profits in Affordable Housing—A Basic Business Typology 227
§ 13.2 Low-Income Housing Tax Credit 228
§ 13.3 Historic Investment Tax Credit 239
§ 13.4 Empowerment Zone Tax Incentives 244
§ 13.5 New Markets Tax Credits 246
§ 13.6 Recent IRS Guidance Regarding Guarantees and Indemnifications 282
§ 13.8 Gulf Opportunity Zone Act of 2005 283
§ 13.9 The Energy Tax Credits (New) 285
Appendix 13A: New Markets Tax Credits Project Compliance/Qualifications/Accounting Projections Checklist (Revised) 290
Chapter Fourteen: Joint Ventures with Universities 293
§ 14.2 IRS Focus on Universities 293
§ 14.4 Research Joint Ventures Generally 301
§ 14.6 Nonresearch Joint Venture Arrangements 301
§ 14.7 Modes of Participation by Universities in Joint Ventures 302
Chapter Fifteen: Business Leagues Engaged in Joint Ventures 309
§ 15.1 Overview 309
§ 15.2 The Five-Prong Test 310
§ 15.3 Unrelated Business Income Tax 312
Chapter Sixteen: Conservation Organizations in Joint Ventures 313
§ 16.2 Conservation and Environmental Protection As a Charitable or Educational Purpose: Public and Private Benefit 313
§ 16.3 Conservation Gifts and §170(h) Contributions 314
§ 16.7 Emerging Issues 321
Chapter Seventeen: International Joint Ventures 325
§ 17.1 Overview 325
§ 17.2 Domestic Charities Expending Funds Abroad 326
§ 17.3 Potential for Abuse: The Use of Charities as Accommodating Parties in International Terrorist Activities 327
§ 17.4 Guidelines for U.S.-Based Charities Engaging in International Aid and International Charities 330
§ 17.11 Application of Foreign Tax Treaties 330
§ 17.12 Current Developments in Cross-Border Charitable Activities 334
Appendix 17A: Redesigned Form 990 (2010) New Schedule F, Statement of Activities Outside the United States (New) 338
Chapter Eighteen: Private Pension Fund Investments in Joint Ventures 343
§ 18.1 Overview 343
§ 18.2 Private Pension Fund Participation in Joint Ventures 343
Chapter Nineteen: Exempt Organizations Investing through Limited Liability Companies 347
§ 19.2 The Basics of LLCs: State and Federal Income Tax Law 347
§ 19.3 Comparison with Other Business Entities 347
§ 19.4 Background and Development of LLCs 349
§ 19.5 Tax Classification of LLCs under Check-the-Box Regulations 349
§ 19.6 Exempt Organizations Wholly Owning Other Entities 352
§ 19.7 IRS Analysis: The Double-Prong Test and Rev. Rul. 98-15 352
§ 19.8 Nonprofit-Sponsored LIHTC Project 354
§ 19.9 Private Foundations as Members of LLCs 354
Chapter Twenty: Debt Restructuring and Asset Protection Issues 357
§ 20.1 Introduction 357
§ 20.2 Overview of Bankruptcy 361
§ 20.3 Automatic Stay 368
§ 20.4 Chapter 11 Plan of Reorganization 370
§ 20.5 Discharge 370
Index 371
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Joint Ventures Involving Tax-Exempt Organizations: 2012 Cumulative Supplement, 3rd Edition (US $150.00)
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