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