Preface xi Acknowledgments xv 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 1 § 1.6 Conservation Joint Ventures 2 § 1.8 Rev. Rul. 98-15 and Joint Venture Structure 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 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 4 § 1.24 Other Developments 4 Chapter 2: Taxation of Charitable Organizations 5 § 2.1 Introduction (Revised) 5 § 2.
2 Categories of Exempt Organizations (Revised) 10 § 2.3 § 501(c)(3) Organizations: Statutory Requirements (Revised) 13 § 2.4 Charitable Organizations: General Requirements 14 § 2.6 Application for Exemption 15 § 2.7 Governance 21 § 2.8 Form 990: Reporting and Disclosure Requirements (Revised) 22 § 2.10 The IRS Audit 24 § 2.11 Charitable Contributions (Revised) 27 Chapter 3: Taxation of Partnerships and Joint Ventures 35 § 3.
1 Scope of Chapter 35 § 3.3 Classification as a Partnership 38 § 3.4 Alternatives to Partnerships 38 § 3.7 Formation of Partnership 38 § 3.8 Tax Basis in Partnership Interest 39 § 3.9 Partnership Operations 39 § 3.11 Sale or Other Disposition of Assets or Interests 40 § 3.12 Other Tax Issues (Revised) 41 Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 47 § 4.
1 Introduction 47 § 4.2 Exempt Organization as General Partner: A Historical Perspective 48 § 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures 50 § 4.9 Conversions from Exempt to For-Profit and from For-Profit to Exempt Entities 50 § 4.10 Analysis of a Virtual Joint Venture 50 Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 53 § 5.1 What Are Private Inurement and Private Benefit? (Revised) 53 § 5.2 Transactions in Which Private Benefit or Inurement May Occur 55 § 5.3 Profit-Making Activities as Indicia of Nonexempt Purpose 57 § 5.
4 Intermediate Sanctions (Revised) 57 § 5.7 State Activity with Respect to Insider Transactions 65 Chapter 6: Engaging in a Joint Venture: The Choices 67 § 6.1 Introduction 67 § 6.2 LLCs (Revised) 68 § 6.3 Use of a For-Profit Subsidiary as Participant in a Joint Venture 69 § 6.5 Private Foundations and Program-Related Investments 73 § 6.6 Nonprofits and Bonds (Revised) 77 § 6.7 Exploring Alternative Structures 79 § 6.
8 Other Approaches 80 Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 83 § 7.2 Prevention of Abusive Tax Shelters 83 § 7.3 Excise Taxes and Penalties 84 Chapter 8: The Unrelated Business Income Tax 85 § 8.1 Introduction 85 § 8.3 General Rule 86 § 8.4 Statutory Exceptions to UBIT (Revised) 87 § 8.5 Modifications to UBIT (Revised) 87 § 8.7 Calculation of UBIT (Revised) 88 Chapter 9: Debt-Financed Income 99 § 9.
1 Introduction 99 § 9.2 Debt-Financed Property 99 § 9.6 The Final Regulations 100 Chapter 10: Limitation on Excess Business Holdings 103 § 10.1 Introduction 103 § 10.2 Excess Business Holdings: General Rules (Revised) 103 § 10.3 Tax Imposed 105 § 10.4 Exclusions 105 Chapter 12: Healthcare Entities in Joint Ventures 109 § 12.1 Overview 109 § 12.
2 Classifications of Joint Ventures 110 § 12.3 Tax Analysis 110 § 12.4 Other Healthcare Industry Issues 113 § 12.5 Preserving the 50/50 Joint Venture 113 § 12.9 Government Scrutiny 114 § 12.11 The Patient Protection and Affordable Care Act of 2010: § 501(r) and Other Statutory Changes Impacting Nonprofit Hospitals 114 § 12.12 The Patient Protection and Affordable Care Act of 2010: ACOs and Co-Ops: New Joint Venture Healthcare Entities 117 Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 119 § 13.2 Nonprofit-Sponsored LIHTC Project (New) 119 § 13.
3 Low-Income Housing Tax Credit (Revised) 120 § 13.4 Historic Investment Tax Credit 122 § 13.6 New Markets Tax Credits (Revised) 126 § 13.10 The Energy Tax Credits 141 § 13.11 The Opportunity Zone Funds: New Section 1400Z-1 and Section 1400Z-2 (Revised) 142 Appendix 13B (New) 165 Chapter 14: Joint Ventures with Universities 183 § 14.1 Introduction 183 § 14.3 Colleges and Universities IRS Compliance Initiative (New) 188 § 14.5 Faculty Participation in Research Joint Ventures 189 § 14.
6 Nonresearch Joint Venture Arrangements 189 § 14.7 Modes of Participation by Universities in Joint Ventures (Revised) 189 Chapter 15: Business Leagues Engaged in Joint Ventures 193 § 15.1 Overview 193 § 15.2 The Five-Prong Test 194 § 15.3 Unrelated Business Income Tax 194 Chapter 16: Conservation Organizations in Joint Ventures 195 § 16.1 Overview 195 § 16.2 Conservation and Environmental Protection as a Charitable or Educational Purpose: Public and Private Benefit 195 § 16.3 Conservation Gifts and § 170(h) Contributions (Revised) 196 § 16.
7 Emerging Issues 210 Chapter 17: International Joint Ventures 211 § 17.5 General Grantmaking Rules 211 § 17.11 Application of Foreign Tax Treaties 212 Chapter 19: Debt Restructuring and Asset Protection Issues 215 § 19.1 Introduction 215 § 19.2 Overview of Bankruptcy 215 § 19.3 The Estate and the Automatic Stay 216 § 19.4 Case Administration 217 § 19.5 Chapter 11 Plan 217 § 19.
6 Discharge 218 Index 219.