A comprehensive, revised, and expanded guide covering tax-exempt organizations engaging in joint ventures Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition examines the liability of, and consequences to, exempt organizations participating in joint ventures with for-profit and other tax-exempt entities. This authoritative guide provides unbridled access to relevant IRC provisions, Treasury regulations, IRS rulings, and pertinent judicial decisions and legislative developments that impact exempt organizations involved in joint ventures. Features in depth analysis of the IRS's requirements for structuring joint ventures to protect a nonprofit's exemption as well as to minimize UBIT Includes sample models, checklists, and numerous citations to Internal Revenue Code sections, Treasury Regulations, case law, and IRS rulings Presents models, guidelines, and suggestions for structuring joint ventures and minimizing the risk of audit Contains detailed coverage of: new Internal Revenue Code requirements impacting charitable hospitals including Section 501(r) and related provisions; university ventures, revised Form 990, with a focus on nonprofits engaged in joint ventures; the IRS's emphasis on good governance practices; international activities by nonprofits; and a comprehensive examination of the New Market Tax Credits and Low Income Housing Tax Credits arena Written by a noted expert in the field, Joint Ventures Involving Tax-Exempt Organizations, Fourth Edition is the most in-depth discussion of this critical topic.

A comprehensive, revised, and expanded guide covering tax-exemptorganizations engaging in joint venturesJoint Ventures Involving Tax-Exempt Organizations, FourthEdition examines the liability of, and consequences to, exemptorganizations participating in joint ventures with for-profit andother tax-exempt entities. This authoritative guide providesunbridled access to relevant IRC provisions, Treasury regulationsIRS rulings, and pertinent judicial decisions and legislativedevelopments that impact exempt organizations involved in jointventures.* Features in depth analysis of the IRS's requirements forstructuring joint ventures to protect a nonprofit's exemption aswell as to minimize UBIT* Includes sample models, checklists, and numerous citations toInternal Revenue Code sections, Treasury Regulations, case law, andIRS rulings* Presents models, guidelines, and suggestions for structuringjoint ventures and minimizing the risk of audit* Contains detailed coverage of: new Internal Revenue Coderequirements impacting charitable hospitals including Section501(r) and related provisions; university ventures, revised Form990, with a focus on nonprofits engaged in joint ventures; theIRS's emphasis on good governance practices; internationalactivities by nonprofits; and a comprehensive examination of theNew Market Tax Credits and Low Income Housing Tax CreditsarenaWritten by a noted expert in the field, Joint VenturesInvolving Tax-Exempt Organizations, Fourth Edition is the mostin-depth discussion of this critical topic.

Preface xxvAcknowledgments xxixAbout the Author xxxiChapter 1: Introduction: Joint Ventures Involving Exempt Organizations 1Chapter 2: Taxation of Charitable Organizations 49Chapter 3: Taxation of Partnerships and Joint Ventures 193Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 291Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 409Chapter 6: Engaging in a Joint Venture: The Choices 489Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 561Chapter 8: The Unrelated Business Income Tax 577Chapter 9: Debt-Financed Income 669Chapter 10: Limitation on Excess Business Holdings 697Chapter 11: Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules 709Chapter 12: Healthcare Entities in Joint Ventures 729Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 939Chapter 14: Joint Ventures with Universities 1101Chapter 15: Business Leagues Engaged in Joint Ventures 1171Chapter 16: Conservation Organizations in Joint Ventures 1199Chapter 17: International Joint Ventures 1235Chapter 18: The Exempt Organization as Lender or Ground Lessor 1291Chapter 19: Debt Restructuring and Asset Protection Issues 1335Index 1399