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| List of Exhibits | |
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| Preface | |
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| About the Authors | |
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| Acknowledgments | |
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| Qualifications Of Tax-Exempt Organizations | |
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| Distinguishing Characteristics of Tax-Exempt Organizations | |
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| Differences between Exempt and Nonexempt Organizations | |
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| Nomenclature | |
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| Ownership and Control | |
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| Role of the Internal Revenue Service | |
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| Suitability as an Exempt Organization | |
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| Start-Up Tax and Financial Considerations | |
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| Choosing the Best Form of Organization | |
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| Qualifying Under IRC Â 501(c)(3) | |
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| Organizational Test | |
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| Operational Test | |
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| Religious Organizations | |
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| Types of Religious Organizations | |
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| Churches | |
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| Religious Orders | |
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| Religious and Apostolic Associations | |
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| Charitable Organizations | |
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| Relief of the Poor | |
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| Promotion of Social Welfare | |
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| Lessening the Burdens of Government | |
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| Advancement of Religion | |
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| Advancement of Education and Science | |
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| Promotion of Health | |
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| Cooperative Hospital Service Organizations | |
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| Educational, Scientific, and Literary Purposes and Prevention of Cruelty to Children and Animals | |
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| Educational Purposes | |
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| Literary Purposes | |
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| Scientific Purposes | |
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| Testing for Public Safety | |
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| Fostering National or International Amateur Sports Competition (But Only If No Part of Its Activities Involves the Provision of Athletic Facilities or Equipment) | |
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| Prevention of Cruelty to Children or Animals | |
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| Civic Leagues and Local Associations of Employees: Â 501(c)(4) | |
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| Comparison of (c)(3) and (c)(4) Organizations | |
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| Qualifying and Nonqualifying Civic Organizations | |
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| Local Associations of Employees | |
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| Neighborhood and Homeowner���s Associations | |
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| Disclosures of Nondeductibility | |
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| Labor, Agricultural, and Horticultural Organizations: Â 501(c)(5) | |
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| Labor Unions | |
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| Agricultural Groups | |
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| Horticultural Groups | |
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| Disclosures of Nondeductibility | |
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| Business Leagues: Â 501(c)(6) | |
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| Basic Characteristics | |
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| Meaning of "Common Business Interest" | |
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| Line of Business | |
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| Rendering Services for Members | |
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| Sources of Revenue | |
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| Membership Categories | |
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| Member Inurement | |
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| Chambers of Commerce and Boards of Trade | |
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| Comparison to  501(c)(5) | |
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| Recognition of Exempt Status | |
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| Formation of a Related Charitable Organization | |
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| Disclosures for Lobbying and Nondeductibility | |
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| Social Clubs: Â 501(c)(7) | |
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| Organizational Requirements and Characteristics | |
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| Member Inurement Prohibited | |
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| Membership Requirements | |
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| Revenue Tests | |
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| Unrelated Business Income Tax | |
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| Filing and Disclosure Requirements | |
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| Instrumentalities of Government and Title-Holding Corporations | |
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| Â 501(c)(1) Instrumentalities of the United States | |
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| Governmental Units | |
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| Qualifying for  501(c)(3) Status | |
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| Â 501(c)(2) Title-Holding Corporations | |
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| Â 501(c)(25) Title-Holding Corporations | |
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| Public Charities | |
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| Distinctions between Public and Private Charities | |
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| "Inherently Public Activity" and Broad Public Support: Â 509(a)(1) | |
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| Community Foundations | |
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| Service-Providing Organizations: Â 509(a)(2) | |
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| Difference between  509(a)(1) and  509(a)(2) | |
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| Supporting Organizations: Â 509(a)(3) | |
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| Testing for Public Safety: Â 509(a)(4) | |
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| Standards For Private Foundations | |
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| Private Foundations—General Concepts | |
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| Why Private Foundations Are Special | |
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| Special Rules Pertaining to Private Foundations | |
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| Application of Taxes to Certain Nonexempt Trusts | |
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| Termination of Private Foundation Status | |
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| Excise Tax Based on Investment Income: IRC Â 4940 | |
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| Formula for Taxable Income | |
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| Capital Gains | |
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| Ponzi Scheme Losses | |
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| Deductions from Gross Investment Income | |
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| Tax-Planning Ideas | |
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| Foreign Foundations | |
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| Timely Payment of Excise Tax | |
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| Exempt Operating Foundations | |
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| Self-Dealing: IRC Â 4941 | |
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| Definition of Self-Dealing | |
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| Sale, Exchange, or Lease of Property | |
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| Loans | |
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| Compensation | |
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| Transactions That Benefit Disqualified Persons | |
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| Payments to Government Officials | |
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| Sharing Space, People, and Expenses | |
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| Indirect Deals | |
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| Property Held by Fiduciaries | |
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| Issues Once Self-Dealing Occurs | |
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| Minimum Distribution Requirements: IRC Â 4942 | |
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| Assets Used to Calculate Minimum Investment Return | |
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| Measuring Fair Market Value | |
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| Distributable Amount | |
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| Qualifying Distributions | |
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| Private Operating Foundations | |
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| Satisfying the Distribution Test | |
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| Excess Business Holdings and Jeopardizing Investments: IRC Â Â 4943 and 4944 | |
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| Excess Business Holdings | |
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| Jeopardizing Investments | |
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| Program-Related Investments | |
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| Penalty Taxes | |
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| Taxable Expenditures: IRC Â 4945 | |
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| Lobbying | |
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| Voter Registration Drives | |
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| Grants to Individuals | |
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| Grants to Public Charities | |
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| Grants to Foreign Organizations | |
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| Expenditure Responsibility Grants | |
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| Noncharitable Expenditures | |
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| Excise Taxes Payable | |
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| Obtaining And Maintaining Tax-Exempt Status | |
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| IRS Filings, Procedures, and Policies | |
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| IRS Determination Process | |
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| Annual Filing of Forms 990 | |
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| Reporting Organizational Changes to the IRS | |
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| Weathering an IRS Examination | |
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| When Organization Loses Its Tax-Exempt Status | |
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| Maintaining Exempt Status | |
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| Checklists | |
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| Private Inurement and Intermediate Sanctions | |
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| Defining Inurement | |
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| Salaries and Other Compensation | |
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| Finding Salary Statistics | |
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| Housing and Meals | |
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| Purchase, Lease, or Sale of Property or Services | |
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| Loans and Guarantees | |
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| For-Profit to Nonprofit and Vice Versa | |
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| Services Rendered for Individuals | |
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| Joint Ventures | |
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| Intermediate Sanctions | |
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| Unrelated Business Income | |
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| IRS Scrutiny of Unrelated Business Income | |
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| History of the Unrelated Business Income Tax | |
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| Consequences of Receiving UBI | |
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| Definition of Trade or Business | |
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| What Is Unrelated Business Income? | |
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| "Regularly Carried On" | |
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| "Substantially Related" | |
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| Unrelated Activities | |
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| The Exceptions | |
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| Income Modifications | |
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| Calculating and Minimizing Taxable Income | |
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| Debt-Financed Property | |
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| Museums | |
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| Travel Tours | |
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| Publishing | |
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| Relationships with Other Organizations and Businesses | |
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| Creation of (c)(3) by (c)(4), (5), or (6) | |
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| Alliances with Investors | |
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| Creation of a For-Profit Corporate Subsidiary | |
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| Active Business Relationships | |
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| Electioneering and Lobbying | |
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| Election Campaign Involvement | |
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| Voter Education versus Candidate Promotion | |
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| Tax on Political Expenditures | |
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| Lobbying Activity of  501(c)(3) Organizations | |
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| Permissible Amounts of Lobbying | |
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| Lobbying Limits for  501(c)(4), (5), (6), and Other Exempt Organizations | |
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| Advocacy and Nonpartisan Analysis | |
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| Deductibility and Disclosures | |
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| Overview of Deductibility | |
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| The Substantiation and Quid Pro Quo Rules | |
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| Valuing Donor Benefits | |
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| Unrelated Business Income Aspects of Fund-Raising | |
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| State and Local Regulations | |
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| Employment Taxes | |
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| Distinctions Between Employees and Independent Contractors | |
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| Ministers | |
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| Reporting Requirements | |
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| Mergers, Bankruptcies, and Terminations | |
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| Mergers and Other Combinations | |
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| Bankruptcy | |
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| Terminations | |
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| Table of Cases | |
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| Table of IRS Revenue Rulings | |
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| Table of IRS Revenue Procedures | |
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| Index | |