| Acknowledgments | | xiii | |
| Preface | | xv | |
| Chapter One Introduction: Joint Ventures Involving Exempt Organizations Generally |
| | 1 | |
| § 1.2 Joint Ventures in General |
| | 1 | |
| § 1.3 Healthcare Joint Ventures |
| | 1 | |
| § 1.4 University Joint Ventures |
| | 2 | |
| § 1.5 Low-Income Housing Joint Ventures |
| | 2 | |
| § 1.20 "Intangibles" Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture |
| | 2 | |
| § 1.24 Other Developments |
| | 2 | |
| Chapter Two Taxation of Charitable Organizations |
| | 3 | |
| § 2.3 Section 501(c) Organizations: Structural Elements |
| | 3 | |
| § 2.4 Statutory Requirements |
| | 3 | |
| § 2.8 Application for Exemption |
| | 12 | |
| § 2.9 Reporting Requirements |
| | 14 | |
| § 2.9A Redesigned Form 990 (New) |
| | 16 | |
| § 2.13A Focus on Good Governance (New) |
| | 56 | |
| Appendix 2A Redesigned Form 990 (2010) (New) |
| | 61 | |
| Chapter Three Taxation of Partnerships and Joint Ventures |
| | 75 | |
| | 75 | |
| § 3.2 Qualifying as a Partnership |
| | 75 | |
| § 3.6 Allocation of Profits, Losses, and Credits |
| | 75 | |
| § 3.7 Formation of Partnership |
| | 76 | |
| § 3.8 Tax Basis in Partnership Interests |
| | 77 | |
| § 3.9 Partnership Operations |
| | 77 | |
| | 78 | |
| Chapter Four Overview: Joint Ventures Involving Exempt Organizations |
| | 81 | |
| § 4.2 Exempt Organization as a General Partner: A Historical Perspective |
| | 81 | |
| § 4.4 Joint Ventures with Other Exempt Organizations |
| | 83 | |
| § 4.5 New Scheme for Analyzing Joint Ventures |
| | 83 | |
| § 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures |
| | 84 | |
| § 4.8 Use of a Subsidiary as Participant in a Joint Venture |
| | 86 | |
| § 4.8A Social Entrepreneurs: Exploring Alternative Structures (New) |
| | 92 | |
| § 4.9 Use of a Supporting Organization in a Joint Venture |
| | 98 | |
| § 4.12 Exempt Organization as Lender or Ground Lessor |
| | 103 | |
| § 4.14 Reporting Requirements |
| | 104 | |
| Appendix 4A Joint Venture Checklist (Revised) |
| | 109 | |
| Appendix 4B Redesigned Form 990 (2010 Schedule R, Related Organizations and Unrelated Partnerships) (New) |
| | 115 | |
| Appendix 4C Model Joint Venture Participation Policy (New) |
| | 121 | |
| Chapter Five Private Benefit, Private Inurement, and Excess Benefit Transactions |
| | 125 | |
| § 5.1 What Are Private Inurement and Private Benefit? |
| | 125 | |
| § 5.2 Transactions in Which Private Benefit or Inurement May Occur |
| | 126 | |
| § 5.4 Intermediate Sanctions |
| | 129 | |
| | 133 | |
| Chapter Six The Exempt Organization as Lender or Ground Lessor |
| | 135 | |
| | 135 | |
| § 6.4 Participating Loans |
| | 135 | |
| § 6.5 Ground Lease with Leasehold Mortgage |
| | 135 | |
| § 6.6 Sale of Undeveloped Land |
| | 136 | |
| | 136 | |
| Chapter Seven Exempt Organizations as Accommodating Parties in Tax Shelter Transactions |
| | 137 | |
| § 7.2 Prevention of Abusive Tax Shelters |
| | 137 | |
| § 7.3 Excise Taxes and Penalties |
| | 140 | |
| Chapter Eight The Unrelated Business Income Tax |
| | 143 | |
| | 143 | |
| | 144 | |
| § 8.4 Statutory Exceptions to UBIT |
| | 145 | |
| § 8.5 Modifications to UBIT |
| | 145 | |
| § 8.7 Calculation of UBIT |
| | 147 | |
| § 8.8 Governmental Scrutiny and Legislative Initiatives |
| | 147 | |
| Chapter Nine Debt-Financed Income |
| | 151 | |
| | 151 | |
| § 9.2 Debt-Financed Property |
| | 151 | |
| § 9.3 The §514(c)(9) Exception |
| | 152 | |
| Chapter Ten Limitation on Excess Business Holdings |
| | 153 | |
| | 153 | |
| § 10.2 Excess Business Holdings: General Rules |
| | 153 | |
| | 154 | |
| Chapter Eleven Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules |
| | 155 | |
| § 11.3 Internal Revenue Code §168(h) |
| | 155 | |
| § 11.5 Restrictions on Tax-Exempt Use Property |
| | 155 | |
| Chapter Twelve Healthcare Entities in Joint Ventures |
| | 159 | |
| | 159 | |
| § 12.4 Other Healthcare Industry Issues |
| | 162 | |
| § 12.7 Joint Operating Agreements |
| | 170 | |
| § 12.8 UBIT Implications of Hospital Joint Ventures |
| | 170 | |
| § 12.9 Government Scrutiny |
| | 171 | |
| § 12.9A The Patient Protection and Affordable Care Act of 2010: §501(r) and Other Statutory Changes Impacting Nonprofit Hospitals (New) |
| | 178 | |
| § 12.9B The Patient Protection and Affordable Care Act of 2010: ACOs and CO-OPs: New Joint Venture Health Care Entities (New) |
| | 200 | |
| Appendix 12B Redesigned Form 990 (2010), Schedule H, Hospitals (New) |
| | 213 | |
| Appendix 12C Model Joint Venture Participation Policy (New) |
| | 222 | |
| Chapter Thirteen Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs |
| | 227 | |
| § 13.1 Relationships between Nonprofits and For-Profits in Affordable Housing---A Basic Business Typology |
| | 227 | |
| § 13.2 Low-Income Housing Tax Credit |
| | 228 | |
| § 13.3 Historic Investment Tax Credit |
| | 239 | |
| § 13.4 Empowerment Zone Tax Incentives |
| | 244 | |
| § 13.5 New Markets Tax Credits |
| | 246 | |
| § 13.6 Recent IRS Guidance Regarding Guarantees and Indemnifications |
| | 282 | |
| § 13.8 Gulf Opportunity Zone Act of 2005 |
| | 283 | |
| § 13.9 The Energy Tax Credits (New) |
| | 285 | |
| Appendix 13A New Markets Tax Credits Project Compliance/Qualifications/Accounting Projections Checklist (Revised) |
| | 290 | |
| Chapter Fourteen Joint Ventures with Universities |
| | 293 | |
| § 14.2 IRS Focus on Universities |
| | 293 | |
| § 14.4 Research Joint Ventures Generally |
| | 301 | |
| § 14.6 Nonresearch Joint Venture Arrangements |
| | 301 | |
| § 14.7 Modes of Participation by Universities in Joint Ventures |
| | 302 | |
| Chapter Fifteen Business Leagues Engaged in Joint Ventures |
| | 309 | |
| | 309 | |
| § 15.2 The Five-Prong Test |
| | 310 | |
| § 15.3 Unrelated Business Income Tax |
| | 312 | |
| Chapter Sixteen Conservation Organizations in Joint Ventures |
| | 313 | |
| § 16.2 Conservation and Environmental Protection As a Charitable or Educational Purpose: Public and Private Benefit |
| | 313 | |
| § 16.3 Conservation Gifts and §170(h) Contributions |
| | 314 | |
| | 321 | |
| Chapter Seventeen International Joint Ventures |
| | 325 | |
| | 325 | |
| § 17.2 Domestic Charities Expending Funds Abroad |
| | 326 | |
| § 17.3 Potential for Abuse: The Use of Charities as Accommodating Parties in International Terrorist Activities |
| | 327 | |
| § 17.4 Guidelines for U.S.-Based Charities Engaging in International Aid and International Charities |
| | 330 | |
| § 17.11 Application of Foreign Tax Treaties |
| | 330 | |
| § 17.12 Current Developments in Cross-Border Charitable Activities |
| | 334 | |
| Appendix 17A Redesigned Form 990 (2010) New Schedule F, Statement of Activities Outside the United States (New) |
| | 338 | |
| Chapter Eighteen Private Pension Fund Investments in Joint Ventures |
| | 343 | |
| | 343 | |
| § 18.2 Private Pension Fund Participation in Joint Ventures |
| | 343 | |
| Chapter Nineteen Exempt Organizations Investing through Limited Liability Companies |
| | 347 | |
| § 19.2 The Basics of LLCs: State and Federal Income Tax Law |
| | 347 | |
| § 19.3 Comparison with Other Business Entities |
| | 347 | |
| § 19.4 Background and Development of LLCs |
| | 349 | |
| § 19.5 Tax Classification of LLCs under Check-the-Box Regulations |
| | 349 | |
| § 19.6 Exempt Organizations Wholly Owning Other Entities |
| | 352 | |
| § 19.7 IRS Analysis: The Double-Prong Test and Rev. Rul. 98-15 |
| | 352 | |
| § 19.8 Nonprofit-Sponsored LIHTC Project |
| | 354 | |
| § 19.9 Private Foundations as Members of LLCs |
| | 354 | |
| Chapter Twenty Debt Restructuring and Asset Protection Issues |
| | 357 | |
| | 357 | |
| § 20.2 Overview of Bankruptcy |
| | 361 | |
| | 368 | |
| § 20.4 Chapter 11 Plan of Reorganization |
| | 370 | |
| | 370 | |
| Index | | 371 | |
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