Preface ix PART I QUALIFICATIONS OF TAX-EXEMPT ORGANIZATIONS 1 CHAPTER 2 Qualifying Under IRC § 501(c)(3) 3 *§ 2.2 Operational Test 3 *CHAPTER 3 Churches 5 § 3.2 Churches 5 CHAPTER 4 Charitable Organizations 7 § 4.2 Promotion of Social Welfare 7 *§ 4.3 Lessening Burdens of Government 7 § 4.6 Promotion of Health 8 CHAPTER 5 Educational, Scientific, and Literary Purposes, and Prevention of Cruelty to Children and Animals 19 § 5.1 Educational Purposes 19 § 5.4 Testing for Public Safety 20 CHAPTER 6 Civic Leagues and Local Associations of Employees: § 501(c)(4) 21 § 6.
1 Comparison of (c)(3) and (c)(4) Organizations 21 *§ 6.2 Qualifying and Nonqualifying Civic Organizations 22 *§ 6.4 Neighborhood and Homeowner''s Associations 24 § 6.5 Disclosures of Nondeductibility 24 CHAPTER 8 Business Leagues: § 501(c)(6) 25 § 8.2 Meaning of "Common Business Interest" 25 § 8.3 Line of Business 25 *§ 8.4 Rendering Services for Members 26 CHAPTER 9 Social Clubs: § 501(c)(7) 27 *§ 9.1 Organizational Requirements and Characteristics 27 § 9.
4 Revenue Tests 28 CHAPTER 10 Instrumentalities of Government and Title-Holding Organizations 29 § 10.2 Governmental Units 29 *§ 10.3 Qualifying for § 501(c)(3) Status 29 CHAPTER 11 Public Charities 33 § 11.1 Distinction between Public and Private Charities 33 *§ 11.2 "Inherently Public Activity" and Broad Public Support § 509(a)(1) 33 § 11.6 Supporting Organizations § 509(a)(3) 36 PART II STANDARDS FOR PRIVATE FOUNDATIONS 47 CHAPTER 12 Private Foundations--General Concepts 49 § 12.2 Special Rules Pertaining to Private Foundations 49 § 12.4 Termination of Private Foundation Status 50 CHAPTER 13 Excise Tax Based on Investment Income: IRC § 4940 55 *§ 13.
2 Capital Gains 55 CHAPTER 14 Self-Dealing: IRC § 4941 57 § 14.1 Definition of Self-Dealing 57 *§ 14.2 Sale, Exchange, or Lease of Property 58 § 14.3 Loans 60 § 14.4 Compensation 61 § 14.5 Transactions That Benefit Disqualified Persons 62 *§ 14.7 Sharing Space, People, and Expenses 63 *§ 14.8 Indirect Deals 64 § 14.
9 Property Held by Fiduciaries 65 § 14.10 Issues Once Self-Dealing Occurs 65 CHAPTER 15 Minimum Distribution Requirements: IRC § 4942 67 § 15.1 Assets Used to Calculate Minimum Investment Return 67 § 15.2 Measuring Fair Market Value 68 *§ 15.4 Qualifying Distributions 68 § 15.6 Satisfying the Distribution Test 77 CHAPTER 16 Excess Business Holdings and Jeopardizing Investments: IRC §§ 4943 and 4944 81 § 16.1 Excess Business Holdings 81 § 16.2 Jeopardizing Investments 83 § 16.
3 Program-Related Investments 84 § 16.4 Penalty Taxes 86 CHAPTER 17 Taxable Expenditures: IRC § 4945 87 § 17.1 Lobbying 87 *§ 17.3 Grants to Individuals 88 *§ 17.4 Grants to Public Charities 91 *§ 17.5 Grants to Foreign Organizations 94 § 17.8 Excise Tax Payable 126 PART III OBTAINING AND MAINTAINING TAX-EXEMPT STATUS 127 CHAPTER 18 IRS Filings, Procedures, and Policies 129 *§ 18.1 Determination Process 129 *§ 18.
2 Annual Filing of Forms 990 141 § 18.3 Reporting Organizational Changes to the IRS 148 § 18.4 Weathering an IRS Examination 149 *§ 18.5 When an Organization Loses its Tax-Exempt Status 150 CHAPTER 19 Maintaining Exempt Status 169 § 19.1 Checklists 169 CHAPTER 20 Private Inurement and Intermediate Sanctions 175 § 20.1 Defining Inurement 176 § 20.2 Salaries and Other Compensation 177 *§ 20.4 Finding Salary Statistics 177 § 20.
8 Services Rendered for Individuals 178 § 20.10 Intermediate Sanctions 178 CHAPTER 21 Unrelated Business Income 179 § 21.1 IRS Scrutiny of Unrelated Business Income 179 § 21.4 Definition of Trade or Business 180 § 21.5 What Is Unrelated Business Income? 180 *§ 21.7 "Substantially Related" 180 *§ 21.8 Unrelated Activities 182 § 21.10 Income Modifications 185 *§ 21.
11 Calculating and Minimizing Taxable Income 186 § 21.12 Debt-Financed Property 187 § 21.13 Museums 188 § 21.15 Publishing 188 CHAPTER 23 Electioneering and Lobbying 189 § 23.1 Election Campaign Involvement 189 § 23.2 Voter Education versus Candidate Promotion 189 CHAPTER 24 Deductibility and Disclosures 191 *§ 24.1 Overview of Deductibility 191 § 24.2 Substantiation and Quid Pro Quo Rules 195 CHAPTER 25 Employment Taxes 197 § 25.
2 Ministers 197 Index 201.