Joint Ventures Involving Tax-Exempt Organizations

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.

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