I gratefully acknowledge the assistance of my colleagues at Blank Rome, LLP, especially Gayle Forst for her contributions and time in the research and review of the manuscript of the Supplement. I want to call attention to the work of Isak Khorets, graduate student at the Georgetown University Law Center, for his research on Section 4960; Amanda H. Nussbaum, who presented at Georgetown University Law Center on UBIT in PE practices, qualified transportation fringe benefits, and qualified sponsorship payments; Sean Delany and Jeremy Steckel, for allowing me to review their article “Balancing Public and Private Interest in Pay for Success Programs: Should We Care About the Private Benefit Doctrine?”; and Paul Saint-Pierre, the principal advisor of PSP Advisors, LLC, for his draft of the tax compliance checklist for U.S. taxpayers investing in qualified opportunity funds, which is included as an appendix to Chapter 13. I also thank Ronald Schutz at Alliant Group for his review and draft of the current of developments regarding conservation organizations.

I especially acknowledge Linda Schrader, whose extraordinary kindness and sensitivity have been invaluable in the preparation of the manuscript as well as her coordination with the staff of John Wiley & Sons; Linda has been critical to the entire process over the decades.