Presents models, guidelines, and suggestions for structuring joint ventures and minimizing the risk of
Table of Contents
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
