Title Details

Preface.

Chapter One: Introduction: Joint Ventures Involving Exempt Organizations Generally.

* § 1.2 Joint Ventures in General.

* § 1.3 Healthcare Joint Ventures.

* § 1.4 University Joint Ventures.

* § 1.5 Low-Income Housing Joint Ventures.

* § 1.20 ‘‘Intangibles’’ Licensed by Nonprofit to For-Profit Subsidiary or Joint Venture.

* § 1.24 Other Developments.

Chapter Two: Taxation of Charitable Organizations.

* § 2.4 Statutory Requirements.

* § 2.8 Application for Exemption.

* § 2.9 Reporting Requirements.

* § 2.9A Redesigned 2008 Form 990 (New).

* § 2.13A Focus on Good Governance (New).

*Appendix 2A (New): Redesigned Form 990 (2008).

Chapter Three: Taxation of Partnerships and Joint Ventures.

* § 3.1 Scope of Chapter.

* § 3.2 Qualifying as a Partnership.

* § 3.6 Allocation of Profits, Losses, and Credits.

* § 3.9 Partnership Operations.

§ 3.12 Other Tax Issues.

Chapter Four: Overview: Joint Ventures Involving Exempt Organizations.

* § 4.2 Exempt Organization as General Partner: A Historical Perspective.

§ 4.4 Joint Ventures with other Exempt Organizations.

* § 4.6 Revenue Ruling 2004-51 and Ancillary Joint Ventures.

* § 4.8 Use of a Subsidiary as Participant in a Joint Venture.

* § 4.8A A Social Entrepreneurs: Operating without Exemption (New).

§ 4.9 Use of a Supporting Organization in a Joint Venture.

* § 4.14 Reporting Requirements.

*Appendix 4B (New): Redesigned Form 990 (2008) New Schedule R, Related Organizations and Unrelated Partnerships.

*Appendix 4C (New): Model Joint Venture Participation Policy.

Chapter Five: Private Benefit, Private Inurement, and Excess Benefit Transactions.

* § 5.1 What are Private Inurement and Private Benefit.

* § 5.2 Transactions in Which Private Benefit or InurementMay Occur.

* § 5.4 Intermediate Sanctions.

Chapter Seven: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions.

* § 7.2 Prevention of Abusive Tax Shelters.

* § 7.3 Excise Taxes and Penalties.

Chapter Eight: The Unrelated Business Income Tax.

* § 8.1 Introduction.

* § 8.3 General Rule.

* § 8.5 Modifications to UBIT.

* § 8.8 Governmental Scrutiny and Legislative Initiatives.

Chapter Nine: Debt-Financed Income.

* § 9.2 Debt-Financed Property.

Chapter Ten: Limitation on Excess Business Holdings.

* § 10.1 Introduction.

* § 10.2 Excess Business Holdings: General Rules.

Chapter Eleven: Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules.

* § 11.5 Restrictions on Tax-Exempt Use Property.

Chapter Twelve: Healthcare Entities in Joint Ventures.

* § 12.3 Tax Analysis.

* § 12.4 Other Healthcare Industry Issues.

* § 12.7 Joint Operating Agreements.

§ 12.8 UBIT Implications of Hospital Joint Ventures.

* § 12.9 Government Scrutiny.

*Appendix 12B (New): Redesigned Form 990 (2008) Schedule H, Hospitals.

*Appendix 12C (New): Model Joint Venture Participation Policy.

Chapter Thirteen: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs.

* § 13.2 Low-Income Housing Tax Credit.

* § 13.3 Historic Investment Tax Credit.

* § 13.5 New Markets Tax Credits.

* § 13.6 Recent IRS Guidance Regarding Guarantees and Indemnifications.

* § 13.8 Gulf Zone Opportunity Act of 2005.

Chapter Fourteen: Joint Ventures with Universities.

* § 14.2 IRS Focus on Universities.

* § 14.7 Modes of Participation by Universities in Joint Ventures.

Chapter Sixteen: Conservation Organizations in Joint Ventures.

* § 16.3 Conservation Gifts and §170(h) Contributions.

* § 16.7 Emerging Issues.

Chapter Seventeen: International Joint Ventures.

* § 17.1 Overview.

* § 17.3 Potential for Abuse: The Use of Charities as Accommodating Parties in International Terrorist Activities.

* § 17.4 Guidelines for U.S.-Based Charities Engaging in International Aid and International Charities.

* § 17.12 Current Developments in Cross-Border Charitable Activities.

*Appendix 17A (New): Redesigned Form 990 (2008) New Schedule F, Statement of Activities Outside the United States.

Chapter Eighteen: Private Pension Fund Investments in Joint Ventures.

* § 18.1 Overview.

* § 18.2 Private Pension Fund Participation in Joint Ventures.

Chapter Ninteen: Exempt Organizations Investing through Limited Liability Companies.

* § 19.2 The Basics of LLCs: State and Federal Income Tax Law.

* § 19.3 Comparison with Other Business Entities.

* § 19.5 Tax Classification of LLCs Under Check-the-Box Regulations.

* § 19.6 Exempt Organizations Wholly Owning Other Entities.

* § 19.7 IRS Analysis: The Double-Prong Test and Rev. Rul. 95-15.

* § 19.8 Nonprofit-Sponsored LIHTC Project.

* § 19.9 Private Foundations as Members of LLCs.

Chapter Twenty: Debt Restructuring and Asset Protection Issues.

* § 20.1 Introduction.

* § 20.2 Overview of Bankruptcy.

* § 20.3 Automatic Stay.

* § 20.4 Chapter 11 Plan of Reorganization.

* § 20.5 Discharge.

Index.