Preface xi Acknowledgments xiv Chapter 1: Introduction: Joint Ventures Involving Exempt Organizations 1 § 1.4 University Joint Ventures 1 § 1.5 Low-Income Housing and New Markets Tax Credit Joint Ventures (Revised) 1 § 1.6 Conservation Joint Ventures 2 § 1.10 Ancillary Joint Ventures: Rev. Rul. 2004-51 2 § 1.14 The Exempt Organization as a Lender or Ground Lessor 2 § 1.
15 Partnership Taxation (Revised) 3 § 1.17 Use of a Subsidiary as a Participant in a Joint Venture 3 § 1.22 Limitation on Private Foundation''s Activities That Limit Excess Business Holdings (New) 3 § 1.24 Other Developments 4 Chapter 2: Taxation of Charitable Organizations 5 § 2.1 Introduction 5 § 2.2 Categories of Exempt Organizations 5 § 2.3 §501(c)(3) Organizations: Statutory Requirements (Revised) 5 § 2.6 Application for Exemption (Revised) 6 § 2.
7 Governance (Revised) 12 § 2.8 Form 990: Reporting and Disclosure Requirements 13 § 2.10 The IRS Audit (New) 14 § 2.11 Charitable Contributions (Revised) 17 Chapter 3: Taxation of Partnerships and Joint Ventures 25 § 3.3 Classification as a Partnership 25 § 3.4 Alternatives to Partnerships 25 § 3.8 Tax Basis in Partnership Interest 26 § 3.9 Partnership Operations 26 § 3.
11 Sale or Other Disposition of Assets or Interests (Revised) 27 § 3.12 Other Tax Issues (Revised) 27 Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 31 § 4.2 Exempt Organization as General Partner: A Historical Perspective 31 § 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures (New) 32 § 4.9 Conversions from Exempt to For-Profit and from For-Profit to Exempt Entities (New) 32 § 4.10 Analysis of a Virtual Joint Venture 33 Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 35 § 5.1 What Are Private Inurement and Private Benefit? (Revised) 35 § 5.2 Transactions in Which Private Benefit or Inurement May Occur 36 § 5.
3 Profit-Making Activities as Indicia of Nonexempt Purpose 37 § 5.4 Intermediate Sanctions (Revised) 37 § 5.7 State Activity with Respect to Insider Transactions 38 Chapter 6: Engaging in a Joint Venture: The Choices 41 § 6.2 LLCs 41 § 6.3 Use of a For-Profit Subsidiary as Participant in a Joint Venture (Revised) 41 § 6.5 Private Foundations and Program-Related Investments (Revised) 45 § 6.6 Nonprofits and Bonds 50 § 6.7 Exploring Alternative Structures 52 § 6.
8 Other Approaches (Revised) 52 Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 55 § 7.2 Prevention of Abusive Tax Shelters (Revised) 55 § 7.3 Excise Taxes and Penalties 56 Chapter 8: The Unrelated Business Income Tax 57 § 8.1 Introduction 57 § 8.3 General Rule (Revised) 58 Chapter 9: Debt-Financed Income 59 § 9.1 Introduction 59 § 9.2 Debt-Financed Property 59 § 9.6 The Final Regulations (New) 59 Chapter 10: Limitation on Excess Business Holdings 63 § 10.
1 Introduction 63 § 10.2 Excess Business Holdings: General Rules (Revised) 63 § 10.3 Tax Imposed 63 § 10.4 Exclusions (Revised) 63 Chapter 12: Healthcare Entities in Joint Ventures 67 § 12.2 Classifications of Joint Ventures 67 § 12.3 Tax Analysis 67 § 12.4 Other Healthcare Industry Issues 68 § 12.5 Preserving the 50/50 Joint Venture 68 § 12.
9 Government Scrutiny 69 § 12.11 The Patient Protection and Affordable Care Act of 2010: §501(r) and Other Statutory Changes Impacting Nonprofit Hospitals 69 § 12.12 The Patient Protection and Affordable Care Act of 2010: ACOs and Co-Ops: New Joint Venture Healthcare Entities 72 Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 75 § 13.3 Low-Income Housing Tax Credit 75 § 13.4 Historic Investment Tax Credit 76 § 13.6 New Markets Tax Credits (Revised) 80 § 13.10 The Energy Tax Credits (Revised) 94 Chapter 14: Joint Ventures with Universities 97 § 14.5 Faculty Participation in Research Joint Ventures 97 § 14.
6 Nonresearch Joint Venture Arrangements 97 § 14.7 Modes of Participation by Universities in Joint Ventures 98 Chapter 15: Business Leagues Engaged in Joint Ventures 101 § 15.1 Overview 101 § 15.2 The Five-Prong Test 102 § 15.3 Unrelated Business Income Tax 102 Chapter 16: Conservation Organizations in Joint Ventures 103 § 16.1 Overview 103 § 16.2 Conservation and Environmental Protection as a Charitable or Educational Purpose: Public and Private Benefit 103 § 16.3 Conservation Gifts and §170(h) Contributions (Revised) 104 § 16.
7 Emerging Issues 114 Chapter 17: International Joint Ventures 117 § 17.5 General Grantmaking Rules (New) 117 § 17.11 Application of Foreign Tax Treaties (Revised) 118 Chapter 19: Debt Restructuring and Asset Protection Issues 121 § 19.2 Overview of Bankruptcy (Revised) 121 § 19.3 The Estate and the Automatic Stay (Revised) 121 § 19.4 Case Administration (New) 122 § 19.5 Chapter 11 Plan (Revised) 122 Index 125.