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End User License Agreement
by Michael I. Sanders
Joint Ventures Involving Tax-Exempt Organizations, 4th Edition
Cover
Preface
NOTES
Acknowledgments
CHAPTER 1: Introduction: Joint Ventures Involving Exempt Organizations
§ 1.4 UNIVERSITY JOINT VENTURES
§ 1.5 LOW-INCOME HOUSING AND NEW MARKETS TAX CREDIT JOINT VENTURES
§ 1.6 CONSERVATION JOINT VENTURES
§ 1.8 REV. RUL. 98-15 AND JOINT VENTURE STRUCTURE
§ 1.10 ANCILLARY JOINT VENTURES: REV. RUL. 2004-51
§ 1.14 THE EXEMPT ORGANIZATION AS A LENDER OR GROUND LESSOR
§ 1.15 PARTNERSHIP TAXATION
§ 1.17 USE OF A SUBSIDIARY AS A PARTICIPANT IN A JOINT VENTURE
§ 1.22 LIMITATION ON PRIVATE FOUNDATION'S ACTIVITIES THAT LIMIT EXCESS BUSINESS HOLDINGS
§ 1.24 OTHER DEVELOPMENTS
CHAPTER 2: Taxation of Charitable Organizations
§ 2.1 INTRODUCTION (REVISED)
§ 2.2 CATEGORIES OF EXEMPT ORGANIZATIONS (REVISED)
§ 2.3 § 501(C)(3) ORGANIZATIONS: STATUTORY REQUIREMENTS (REVISED)
§ 2.4 CHARITABLE ORGANIZATIONS: GENERAL REQUIREMENTS
§ 2.6 APPLICATION FOR EXEMPTION
§ 2.7 GOVERNANCE
§ 2.8 FORM 990: REPORTING AND DISCLOSURE REQUIREMENTS (REVISED)
§ 2.10 THE IRS AUDIT
§ 2.11 CHARITABLE CONTRIBUTIONS (REVISED)
NOTES
CHAPTER 3: Taxation of Partnerships and Joint Ventures
§ 3.1 SCOPE OF CHAPTER
§ 3.3 CLASSIFICATION AS A PARTNERSHIP
§ 3.4 ALTERNATIVES TO PARTNERSHIPS
§ 3.7 FORMATION OF PARTNERSHIP
§ 3.8 TAX BASIS IN PARTNERSHIP INTEREST
§ 3.9 PARTNERSHIP OPERATIONS
§ 3.11 SALE OR OTHER DISPOSITION OF ASSETS OR INTERESTS
§ 3.12 OTHER TAX ISSUES (REVISED)
NOTES
CHAPTER 4: Overview: Joint Ventures Involving Exempt Organizations
§ 4.1 INTRODUCTION
§ 4.2 EXEMPT ORGANIZATION AS GENERAL PARTNER: A HISTORICAL PERSPECTIVE
§ 4.6 REVENUE RULING 2004-51 AND ANCILLARY JOINT VENTURES
§ 4.9 CONVERSIONS FROM EXEMPT TO FOR-PROFIT AND FROM FOR-PROFIT TO EXEMPT ENTITIES
§ 4.10 ANALYSIS OF A VIRTUAL JOINT VENTURE
CHAPTER 5: Private Benefit, Private Inurement, and Excess Benefit Transactions
§ 5.1 WHAT ARE PRIVATE INUREMENT AND PRIVATE BENEFIT? (REVISED)
§ 5.2 TRANSACTIONS IN WHICH PRIVATE BENEFIT OR INUREMENT MAY OCCUR
§ 5.3 PROFIT-MAKING ACTIVITIES AS INDICIA OF NONEXEMPT PURPOSE
§ 5.4 INTERMEDIATE SANCTIONS (REVISED)
§ 5.7 STATE ACTIVITY WITH RESPECT TO INSIDER TRANSACTIONS
NOTES
CHAPTER 6: Engaging in a Joint Venture: The Choices
§ 6.1 INTRODUCTION
§ 6.2 LLCS (REVISED)
§ 6.3 USE OF A FOR-PROFIT SUBSIDIARY AS PARTICIPANT IN A JOINT VENTURE
§ 6.5 PRIVATE FOUNDATIONS AND PROGRAM-RELATED INVESTMENTS
§ 6.6 NONPROFITS AND BONDS (REVISED)
§ 6.7 EXPLORING ALTERNATIVE STRUCTURES
§ 6.8 OTHER APPROACHES
NOTES
CHAPTER 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions
§ 7.2 PREVENTION OF ABUSIVE TAX SHELTERS
§ 7.3 EXCISE TAXES AND PENALTIES
NOTES
CHAPTER 8: The Unrelated Business Income Tax
§ 8.1 INTRODUCTION
§ 8.3 GENERAL RULE
§ 8.4 STATUTORY EXCEPTIONS TO UBIT (REVISED)
§ 8.5 MODIFICATIONS TO UBIT (REVISED)
§ 8.7 CALCULATION OF UBIT (REVISED)
NOTES
CHAPTER 9: Debt-Financed Income
§ 9.1 INTRODUCTION
§ 9.2 DEBT-FINANCED PROPERTY
§ 9.6 THE FINAL REGULATIONS
NOTE
CHAPTER 10: Limitation on Excess Business Holdings
§ 10.1 INTRODUCTION
§ 10.2 EXCESS BUSINESS HOLDINGS: GENERAL RULES (REVISED)
§ 10.3 TAX IMPOSED
§ 10.4 EXCLUSIONS
NOTES
CHAPTER 12: Healthcare Entities in Joint Ventures
§ 12.1 OVERVIEW
§ 12.2 CLASSIFICATIONS OF JOINT VENTURES
§ 12.3 TAX ANALYSIS
§ 12.4 OTHER HEALTHCARE INDUSTRY ISSUES
§ 12.5 PRESERVING THE 50/50 JOINT VENTURE
§ 12.9 GOVERNMENT SCRUTINY
§ 12.11 THE PATIENT PROTECTION AND AFFORDABLE CARE ACT OF 2010: § 501(R) AND OTHER STATUTORY CHANGES IMPACTING NONPROFIT HOSPITALS
§ 12.12 THE PATIENT PROTECTION AND AFFORDABLE CARE ACT OF 2010: ACOS AND CO-OPS: NEW JOINT VENTURE HEALTHCARE ENTITIES
NOTES
CHAPTER 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs
§ 13.2 NONPROFIT-SPONSORED LIHTC PROJECT (NEW)
§ 13.3 LOW-INCOME HOUSING TAX CREDIT (REVISED)
§ 13.4 HISTORIC INVESTMENT TAX CREDIT
§ 13.6 NEW MARKETS TAX CREDITS (REVISED)
§ 13.10 THE ENERGY TAX CREDITS
§ 13.11 THE OPPORTUNITY ZONE FUNDS: NEW SECTION 1400Z-1 AND SECTION 1400Z-2 (REVISED)
APPENDIX 13B (NEW)
NOTES
CHAPTER 14: Joint Ventures with Universities
§ 14.1 INTRODUCTION
§ 14.3 COLLEGES AND UNIVERSITIES IRS COMPLIANCE INITIATIVE (NEW)
§ 14.5 FACULTY PARTICIPATION IN RESEARCH JOINT VENTURES
§ 14.6 NONRESEARCH JOINT VENTURE ARRANGEMENTS
§ 14.7 MODES OF PARTICIPATION BY UNIVERSITIES IN JOINT VENTURES (REVISED)
NOTES
CHAPTER 15: Business Leagues Engaged in Joint Ventures
§ 15.1 OVERVIEW
§ 15.2 THE FIVE-PRONG TEST
§ 15.3 UNRELATED BUSINESS INCOME TAX
NOTES
CHAPTER 16: Conservation Organizations in Joint Ventures
§ 16.1 OVERVIEW
§ 16.2 CONSERVATION AND ENVIRONMENTAL PROTECTION AS A CHARITABLE OR EDUCATIONAL PURPOSE: PUBLIC AND PRIVATE BENEFIT
§ 16.3 CONSERVATION GIFTS AND § 170(H) CONTRIBUTIONS (REVISED)
§ 16.7 EMERGING ISSUES
NOTES
CHAPTER 17: International Joint Ventures
§ 17.5 GENERAL GRANTMAKING RULES
§ 17.11 APPLICATION OF FOREIGN TAX TREATIES
NOTES
CHAPTER 19: Debt Restructuring and Asset Protection Issues
§ 19.1 INTRODUCTION
§ 19.2 OVERVIEW OF BANKRUPTCY
§ 19.3 THE ESTATE AND THE AUTOMATIC STAY
§ 19.4 CASE ADMINISTRATION
§ 19.5 CHAPTER PLAN
§ 19.6 DISCHARGE
NOTE
Index
End User License Agreement
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