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Joint Ventures Involving Tax-Exempt Organizations 2012 Cumulative Supplement

ISBN-10: 1118037529

ISBN-13: 9781118037522

Edition: 3rd 2012

Authors: Michael I. Sanders

List price: $100.00
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Description:

This title includes the latest case law, treasury regulations, and IRS rulings to enable nonprofits to maximise their financing without jeopardising their tax-exempt status. This edition is thoroughly updated, includes sample forms, and provides a new chapter on debt restructuring and bankruptcy.
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Book details

List price: $100.00
Edition: 3rd
Copyright year: 2012
Publisher: John Wiley & Sons, Limited
Publication date: 4/30/2012
Binding: Paperback
Pages: 400
Size: 7.25" wide x 10.25" long x 1.00" tall
Weight: 1.430
Language: English

Acknowledgments
Preface
Introduction: Joint Ventures Involving Exempt Organizations Generally
Joint Ventures in General
Healthcare Joint Ventures
University Joint Ventures
Low-Income Housing Joint Ventures
"Intangibles" Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture
Other Developments
Taxation of Charitable Organizations
Section 501(c) Organizations: Structural Elements
Statutory Requirements
Application for Exemption
Reporting Requirements
Redesigned Form 990 (New)
Focus on Good Governance (New)
Redesigned Form 990 (2010) (New)
Taxation of Partnerships and Joint Ventures
Scope of Chapter
Qualifying as a Partnership
Allocation of Profits, Losses, and Credits
Formation of Partnership
Tax Basis in Partnership Interests
Partnership Operations
Other Tax Issues
Overview: Joint Ventures Involving Exempt Organizations
Exempt Organization as a General Partner: A Historical Perspective
Joint Ventures with Other Exempt Organizations
New Scheme for Analyzing Joint Ventures
Revenue Ruling 2004-51 and Ancillary Joint Ventures
Use of a Subsidiary as Participant in a Joint Venture
Social Entrepreneurs: Exploring Alternative Structures (New)
Use of a Supporting Organization in a Joint Venture
Exempt Organization as Lender or Ground Lessor
Reporting Requirements
Joint Venture Checklist (Revised)
Redesigned Form 990 (2010 Schedule R, Related Organizations and Unrelated Partnerships) (New)
Model Joint Venture Participation Policy (New)
Private Benefit, Private Inurement, and Excess Benefit Transactions
What Are Private Inurement and Private Benefit?
Transactions in Which Private Benefit or Inurement May Occur
Intermediate Sanctions
Planning
The Exempt Organization as Lender or Ground Lessor
Overview
Participating Loans
Ground Lease with Leasehold Mortgage
Sale of Undeveloped Land
Guarantees
Exempt Organizations as Accommodating Parties in Tax Shelter Transactions
Prevention of Abusive Tax Shelters
Excise Taxes and Penalties
The Unrelated Business Income Tax
Introduction
General Rule
Statutory Exceptions to UBLT
Modifications to UBIT
Calculation of UBIT
Governmental Scrutiny and Legislative Initiatives
Debt-Financed Income
Introduction
Debt-Financed Property
The �514(c)(9) Exception
Limitation on Excess Business Holdings
Introduction
Excess Business Holdings: General Rules
Exclusions
Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules
Internal Revenue Code �168(h)
Restrictions on Tax-Exempt Use Property
Healthcare Entities in Joint Ventures
Tax Analysis
Other Healthcare Industry Issues
Joint Operating Agreements
UBIT Implications of Hospital Joint Ventures
Government Scrutiny
The Patient Protection and Affordable Care Act of 2010: �501(r) and Other Statutory Changes Impacting Nonprofit Hospitals (New)
The Patient Protection and Affordable Care Act of 2010: ACOs and CO-OPs: New Joint Venture Health Care Entities (New)
Redesigned Form 990 (2010), Schedule H, Hospitals (New)
Model Joint Venture Participation Policy (New)
Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs
Relationships between Nonprofits and For-Profits in Affordable Housing-A Basic Business Typology
Low-Income Housing Tax Credit
Historic Investment Tax Credit
Empowerment Zone Tax Incentives
New Markets Tax Credits
Recent IRS Guidance Regarding Guarantees and Indemnifications
Gulf Opportunity Zone Act of 2005
The Energy Tax Credits (New)
New Markets Tax Credits Project Compliance/Qualifications/Accounting Projections Checklist (Revised)
Joint Ventures with Universities
IRS Focus on Universities
Research Joint Ventures Generally
Nonresearch Joint Venture Arrangements
Modes of Participation by Universities in Joint Ventures
Business Leagues Engaged in Joint Ventures
Overview
The Five-Prong Test
Unrelated Business Income Tax
Conservation Organizations in Joint Ventures
Conservation and Environmental Protection As a Charitable or Educational Purpose: Public and Private Benefit
Conservation Gifts and �170(h) Contributions
Emerging Issues
International Joint Ventures
Overview
Domestic Charities Expending Funds Abroad
Potential for Abuse: The Use of Charities as Accommodating Parties in International Terrorist Activities
Guidelines for U.S.-Based Charities Engaging in International Aid and International Charities
Application of Foreign Tax Treaties
Current Developments in Cross-Border Charitable Activities
Redesigned Form 990 (2010) New Schedule F, Statement of Activities Outside the United States (New)
Private Pension Fund Investments in Joint Ventures
Overview
Private Pension Fund Participation in Joint Ventures
Exempt Organizations Investing through Limited Liability Companies
The Basics of LLCs: State and Federal Income Tax Law
Comparison with Other Business Entities
Background and Development of LLCs
Tax Classification of LLCs under Check-the-Box Regulations
Exempt Organizations Wholly Owning Other Entities
IRS Analysis: The Double-Prong Test and Rev. Rul. 98-15
Nonprofit-Sponsored LMTC Project
Private Foundations as Members of LLCs
Debt Restructuring and Asset Protection Issues
Introduction
Overview of Bankruptcy
Automatic Stay
Plan of Reorganization
Discharge
Index