JOINT VENTURES INVOLVING TAX EXEMPT ORGANIZATIONS 4th Edition by Michael I Sanders ISBN 9781119845607 1119845602

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ISBN 10: 1119845602
ISBN 13: 9781119845607
Author: Michael I Sanders

JOINT VENTURES INVOLVING TAX EXEMPT ORGANIZATIONS 4th Edition Table of contents:

CHAPTER 1: Introduction: Joint Ventures Involving Exempt Organizations

§ 1.4 UNIVERSITY JOINT VENTURES

§ 1.5 LOW‐INCOME HOUSING AND NEW MARKETS TAX CREDIT JOINT VENTURES

§ 1.6 CONSERVATION JOINT VENTURES

§ 1.8 REV. RUL. 98‐15 AND JOINT VENTURE STRUCTURE

§ 1.10 ANCILLARY JOINT VENTURES: REV. RUL. 2004‐51

§ 1.14 THE EXEMPT ORGANIZATION AS A LENDER OR GROUND LESSOR

§ 1.15 PARTNERSHIP TAXATION

§ 1.17 USE OF A SUBSIDIARY AS A PARTICIPANT IN A JOINT VENTURE

§ 1.22 LIMITATION ON PRIVATE FOUNDATION’S ACTIVITIES THAT LIMIT EXCESS BUSINESS HOLDINGS

§ 1.24 OTHER DEVELOPMENTS

Notes

CHAPTER 2: Taxation of Charitable Organizations

§ 2.1 INTRODUCTION

§ 2.2 CATEGORIES OF EXEMPT ORGANIZATIONS (REVISED)

§ 2.3 § 501(C)(3) ORGANIZATIONS: STATUTORY REQUIREMENTS

§ 2.4 CHARITABLE ORGANIZATIONS: GENERAL REQUIREMENTS

§ 2.5 CATEGORIES OF CHARITABLE ORGANIZATIONS (NEW)

§ 2.6 APPLICATION FOR EXEMPTION

§ 2.7 GOVERNANCE

§ 2.8 FORM 990: REPORTING AND DISCLOSURE REQUIREMENTS (REVISED)

§ 2.9 REDESIGNED FORM 990 (NEW)

§ 2.10 THE IRS AUDIT (REVISED)

§ 2.11 CHARITABLE CONTRIBUTIONS (REVISED)

Notes

CHAPTER 3: Taxation of Partnerships and Joint Ventures

§ 3.1 SCOPE OF CHAPTER

§ 3.3 CLASSIFICATION AS A PARTNERSHIP (REVISED)

§ 3.4 ALTERNATIVES TO PARTNERSHIPS

§ 3.7 FORMATION OF PARTNERSHIP

§ 3.8 TAX BASIS IN PARTNERSHIP INTEREST

§ 3.9 PARTNERSHIP OPERATIONS

§ 3.10 PARTNERSHIP DISTRIBUTIONS TO PARTNERS

§ 3.11 SALE OR OTHER DISPOSITION OF ASSETS OR INTERESTS

§ 3.12 OTHER TAX ISSUES

Notes

CHAPTER 4: Overview: Joint Ventures Involving Exempt Organizations

§ 4.1 INTRODUCTION

§ 4.2 EXEMPT ORGANIZATION AS GENERAL PARTNER: A HISTORICAL PERSPECTIVE

§ 4.6 REVENUE RULING 2004‐51 AND ANCILLARY JOINT VENTURES

§ 4.9 CONVERSIONS FROM EXEMPT TO FOR‐PROFIT AND FROM FOR‐PROFIT TO EXEMPT ENTITIES

§ 4.10 ANALYSIS OF A VIRTUAL JOINT VENTURE

CHAPTER 5: 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

§ 5.3 PROFIT‐MAKING ACTIVITIES AS INDICIA OF NONEXEMPT PURPOSE

§ 5.4 INTERMEDIATE SANCTIONS (REVISED)

§ 5.7 STATE ACTIVITY WITH RESPECT TO INSIDER TRANSACTIONS

Notes

CHAPTER 6: Engaging in a Joint Venture: The Choices

§ 6.1 INTRODUCTION

§ 6.2 LLCs

§ 6.3 USE OF A FOR‐PROFIT SUBSIDIARY AS PARTICIPANT IN A JOINT VENTURE (REVISED)

§ 6.5 PRIVATE FOUNDATIONS AND PROGRAM‐RELATED INVESTMENTS (REVISED)

§ 6.6 NONPROFITS AND BONDS

§ 6.7 EXPLORING ALTERNATIVE STRUCTURES (REVISED)

§ 6.8 OTHER APPROACHES

Notes

CHAPTER 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions

§ 7.2 PREVENTION OF ABUSIVE TAX SHELTERS

§ 7.3 EXCISE TAXES AND PENALTIES

Notes

CHAPTER 8: The Unrelated Business Income Tax

§ 8.1 INTRODUCTION

§ 8.3 GENERAL RULE

§ 8.4 STATUTORY EXCEPTIONS TO UBIT

§ 8.5 MODIFICATIONS TO UBIT

§ 8.7 CALCULATION OF UBIT

Notes

CHAPTER 9: Debt‐Financed Income

§ 9.1 INTRODUCTION

§ 9.2 DEBT‐FINANCED PROPERTY

§ 9.3 THE §514(C)(9) EXCEPTION (NEW)

§ 9.6 THE FINAL REGULATIONS

Note

CHAPTER 10: Limitation on Excess Business Holdings

§ 10.1 INTRODUCTION

§ 10.2 EXCESS BUSINESS HOLDINGS: GENERAL RULES (REVISED)

§ 10.3 TAX IMPOSED

§ 10.4 EXCLUSIONS (REVISED)

Notes

CHAPTER 11: Impact on Taxable Joint Ventures: Tax‐Exempt Entity Leasing Rules (New)

§ 11.3 INTERNAL REVENUE CODE § 168(H)

CHAPTER 12: Healthcare Entities in Joint Ventures

§ 12.1 OVERVIEW

§ 12.2 CLASSIFICATIONS OF JOINT VENTURES

§ 12.3 TAX ANALYSIS

§ 12.4 OTHER HEALTHCARE INDUSTRY ISSUES

§ 12.5 PRESERVING THE 50/50 JOINT VENTURE

§ 12.9 GOVERNMENT SCRUTINY

§ 12.11 THE PATIENT PROTECTION AND AFFORDABLE CARE ACT OF 2010: § 501(R) AND OTHER STATUTORY CHANGES IMPACTING NONPROFIT HOSPITALS

§ 12.12 THE PATIENT PROTECTION AND AFFORDABLE CARE ACT OF 2010: ACOS AND CO‐OPS: NEW JOINT VENTURE HEALTHCARE ENTITIES (REVISED)

Notes

CHAPTER 13: Low‐Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs

§ 13.2 NONPROFIT‐SPONSORED LIHTC PROJECT

§ 13.3 LOW‐INCOME HOUSING TAX CREDIT (REVISED)

§ 13.4 HISTORIC INVESTMENT TAX CREDIT

§ 13.6 NEW MARKETS TAX CREDITS (REVISED)

§ 13.10 THE ENERGY TAX CREDITS

§ 13.11 THE OPPORTUNITY ZONE FUNDS: NEW SECTION 1400Z‐1 AND SECTION 1400Z‐2 (REVISED)

APPENDIX 13B

Notes

CHAPTER 14: Joint Ventures with Universities

§ 14.1 INTRODUCTION

§ 14.3 COLLEGES AND UNIVERSITIES IRS COMPLIANCE INITIATIVE

§ 14.5 FACULTY PARTICIPATION IN RESEARCH JOINT VENTURES

§ 14.6 NONRESEARCH JOINT VENTURE ARRANGEMENTS

§ 14.7 MODES OF PARTICIPATION BY UNIVERSITIES IN JOINT VENTURES (REVISED)

Notes

CHAPTER 15: Business Leagues Engaged in Joint Ventures

§ 15.1 OVERVIEW

§ 15.2 THE FIVE‐PRONG TEST (REVISED)

§ 15.3 UNRELATED BUSINESS INCOME TAX

Notes

CHAPTER 16: Conservation Organizations in Joint Ventures

§ 16.1 OVERVIEW

§ 16.2 CONSERVATION AND ENVIRONMENTAL PROTECTION AS A CHARITABLE OR EDUCATIONAL PURPOSE: PUBLIC AND PRIVATE BENEFIT

§ 16.3 CONSERVATION GIFTS AND § 170(H) CONTRIBUTIONS (REVISED)

§ 16.7 EMERGING ISSUES

Notes

CHAPTER 17: International Joint Ventures

§ 17.5 GENERAL GRANTMAKING RULES

§ 17.11 APPLICATION OF FOREIGN TAX TREATIES

Notes

CHAPTER 19: Debt Restructuring and Asset Protection Issues

§ 19.1 INTRODUCTION

§ 19.2 OVERVIEW OF BANKRUPTCY

§ 19.3 THE ESTATE AND THE AUTOMATIC STAY

§ 19.4 CASE ADMINISTRATION

§ 19.5 CHAPTER 11 PLAN

§ 19.6 DISCHARGE

§ 19.7 SPECIAL ISSUES: CONSEQUENCES OF DEBT REDUCTION

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Tags: Michael I Sanders, JOINT VENTURES, TAX EXEMPT ORGANIZATIONS