Acknowledgments.Preface.Chapter one: Introduction: Joint Ventures Involving Exempt Organizations Generally.1.1 Introduction.1.2 Joint Ventures in General.1.
3 Healthcare Joint Ventures.1.4 University Joint Ventures.1.5 Low-Income Housing Joint Ventures.1.6 Conservation Joint Ventures.1.
7 Joint Ventures as Accomodating Parties to Impermissible Tax Shelters.1.8 Joint Venture Structure.1.9 The Exempt Organization in a Joint Venture: Rev. Rul. 98-15.1.
10 Ancillary Joint Ventures: Rev. Rul. 2004-51.1.11 The Exempt Organization as Limited Partner or Non-Managing Member.1.12 Partnerships with Other Exempt Organizations.1.
13 Transfer of Control of Supporting Organization to Another Tax-Exempt Organization.1.14 The Exempt Organization as a Lender or Ground Lessor.1.15 Partnership Taxation.1.16 UBIT Implications From Partnership Activities.1.
17 Use of a Subsidiary as Participant in a Joint Venture.1.18 Limitation on Preferred Returns.1.19 Sharing Staff and/or Facilities: Shared Services Agreement.1.20 "Intangibles" Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture.1.
21 Private Inurement and Private Benefit.1.22 Limitation on Private Foundation''s Activities that Limit Excess Business Holdings.1.23 International Joint Ventures.1.24 Other Developments.Chapter Two: Taxation of Charitable Organizations.
2.1 Introduction.2.2 Categories of Exempt Organizations.2.3 Section 501(c) Organizations: Structural Elements.2.4 Statutory Requirements.
2.5 General Requirements.2.6 Charitable Organizations.2.7 Structure of the IRS.2.8 Application for Exemption.
2.9 Reporting Requirements.2.10 The IRS Audit.2.11 Charitable Contributions.2.12 Car Donation Programs.
2.13 Sarbanes-Oxley and Exempt Organizations.2.14 State Laws.Chapter Three: Taxation of Partnerships and Joint Ventures.3.1 Scope of Chapter.3.
2 Qualifying as a Partnership.3.3 Classification as Partnership.3.4 Alternatives to Partnerships.3.5 Pass-Through Regime: The Conduit Concept.3.
6 Allocation of Profits, Losses, and Credits.3.7 Formation of Partnership.3.8 Tax Basis in Partnership Interests.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.Chapter Four: Overview: Joint Ventures Involving Exempt Organizations.4.1 Introduction.
4.2 Exempt Organization as General Partner: A Historical Perspective.4.3 Exempt Organizations as Limited Partner or LLC Non-Managing Member.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.4.7 UBIT Implications from Joint Venture Activities.4.8 Use of a Subsidiary as Participant in a Joint Venture.4.9 Use of a Supporting Organization in a Joint Venture.
4.10 The IRS Audit.4.11 Conversions from Exempt to For-Profit and from For-Profit to Exempt Entities.4.12 Exempt Organization as Lender or Ground Lessor.4.13 Issuance of Tax-Exempt Bonds.
4.14 Reporting Requirements.Appendix 4A Joint Venture Checklist.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.
3 Profit-Making Activities as Indicia of Nonexempt Purpose.5.4 Intermediate Sanctions.5.5 Case Law.5.6 Planning.5.
7 State Activity with Respect to Insider Transactions.Chapter Six: The Exempt Organization as Lender or Ground Lessor.6.1 Overview.6.2 A Participation as a Lender or Ground Lessor.6.3 Types of Real Estate Loans.
6.4 Participating Loans.6.5 Ground Lease with Leasehold Mortgage.6.6 Sale of Undeveloped Land.6.7 Guarantees.
6.8 Conclusion.Chapter Seven: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions.7.1 Introduction.7.2 Prevention of Abusive Tax Shelters.7.
3 Excise Taxes and Penalties.7.4 Settlement Initiatives.7.5 Abusive Shelters and Tax Credit Programs.Chapter Eight: The Unrelated Business Income Tax.8.1 Introduction.
8.2 Historical and Legisl.