Joint Ventures Involving Tax-Exempt Organizations 2021 Cumulative Supplement

Stay up to date on all relevant regulatory and legislative changes, as well as leading case law, in a complicated area of law In the 2021 Cumulative Supplement to the 4th edition of Joint Ventures Involving Tax-Exempt Organizations, a renowned team of authors delivers the latest updates and developments in the legislation, regulations, and case law governing joint ventures with tax-exempt organizations. Practical and relevant commentary accompanies authoritative reviews of the most recent changes in this complex area of law, creating an essential and comprehensive resource for executives, managers, and other leaders engaged in joint ventures with tax-exempt organizations, as well as the professionals who advise them.

MICHAEL I. SANDERS is the lead partner of Blank Rome's Washington office's tax group with a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit transactions. He is also an adjunct professor at The George Washington University Law School and Georgetown University Law Center. He was recently honored in 2010 by The George Washington University Law School for his 35 years of teaching.

Preface

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 (Revised)

Chapter 2: Taxation of Charitable Organizations

§ 2.1 Introduction

§ 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 (Revised)

§ 2.7 Governance

§ 2.8 Form 990: Reporting and Disclosure Requirements (Revised)

§ 2.10 The IRS Audit (Revised)

§ 2.11 Charitable Contributions (Revised)

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

§ 3.10 Partnership Distributions to Partners (New)

§ 3.11 Sale or Other Disposition of Assets or Interests

§ 3.12 Other Tax Issues

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?

§ 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

Chapter 6: Engaging in a Joint Venture: The Choices

§ 6.1 Introduction

§ 6.2 LLCs

§ 6.3 Use of a For-Profit Subsidiary as Participant in a Joint Venture(Revised)

§ 6.5 Private Foundations and Program-Related Investments

§ 6.6 Nonprofits and Bonds

§ 6.7 Exploring Alternative Structures

§ 6.8 Other Approaches (Revised)

Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions

§ 7.2 Prevention of Abusive Tax Shelters

§ 7.3 Excise Taxes and Penalties

Chapter 8: The Unrelated Business Income Tax

§ 8.1 Introduction

§ 8.3 General Rule

§ 8.4 Statutory Exceptions to UBIT

§ 8.5 Modifications to UBIT

§ 8.7 Calculation of UBIT (Revised)

Chapter 9: Debt-Financed Income

§ 9.1 Introduction

§ 9.2 Debt-Financed Property

§ 9.6 The Final Regulations

Chapter 10: Limitation on Excess Business Holdings

§ 10.1 Introduction

§ 10.2 Excess Business Holdings: General Rules

§ 10.3 Tax Imposed

§ 10.4 Exclusions (Revised)

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

Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs

§ 13.2 Nonprofit-Sponsored LIHTC Project

§ 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

Chapter 14: Joint Ventures with Universities

§ 14.1 Introduction (Revised)

§ 14.3 Colleges and Universities IRS Compliance Initiative

§ 14.5 Faculty Participation in Research Joint Ventures

§ 14.6 Nonresearch Joint Venture Arrangements

§ 14.7 Modes of Participation by Universities in Joint Ventures

Chapter 15: Business Leagues Engaged in Joint Ventures

§ 15.1 Overview

§ 15.2 The Five-Prong Test

§ 15.3 Unrelated Business Income Tax

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

Chapter 17: International Joint Ventures

§ 17.5 General Grantmaking Rules (Revised)

§ 17.11 Application of Foreign Tax Treaties

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 11 Plan

§ 19.6 Discharge

§ 19.7 Special Issues: Consequences of Debt Reduction

Index

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