The Tax Law of Unrelated Business for Nonprofit OrganizationsJohn Wiley & Sons, 2006 M04 26 - 408 pages The Tax Law of Unrelated Business for Nonprofit Organizations is a comprehensive guide to the tax law of unrelated businesses for tax-exempt organizations, written by the leading expert in the field. |
From inside the book
Results 1-5 of 73
Page 3
... Fund , 90 F.2d 286 , 288 ( 7th Cir . 1937 ) . The court also said that “ courts quite gen- erally have extended liberal construction to statutes furthering the encouragement of bequests for purposes which tend toward the public good ...
... Fund , 90 F.2d 286 , 288 ( 7th Cir . 1937 ) . The court also said that “ courts quite gen- erally have extended liberal construction to statutes furthering the encouragement of bequests for purposes which tend toward the public good ...
Page 4
... funds] shall be exempt from taxation under this subtitle [Subti- tle A—income taxes] unless such exemption is denied under section 501 or 503.” The U.S. Supreme Court characterized IRC. § 501(a) as the “linchpin of the statu- tory ...
... funds] shall be exempt from taxation under this subtitle [Subti- tle A—income taxes] unless such exemption is denied under section 501 or 503.” The U.S. Supreme Court characterized IRC. § 501(a) as the “linchpin of the statu- tory ...
Page 7
... funds underlying employee benefit programs.58 Other examples include exemption for professional football leagues, which emanated from the merger of the National Football League and the American Football League;59 and for state-sponsored ...
... funds underlying employee benefit programs.58 Other examples include exemption for professional football leagues, which emanated from the merger of the National Football League and the American Football League;59 and for state-sponsored ...
Page 14
... Funds received by a tax-exempt organization that is acting as an agent for another organization are not taxable income to the exempt organization, and thus are not unrelated business income.146 § 1.7 ORGANIZATIONS SUBJECT TO UNRELATED ...
... Funds received by a tax-exempt organization that is acting as an agent for another organization are not taxable income to the exempt organization, and thus are not unrelated business income.146 § 1.7 ORGANIZATIONS SUBJECT TO UNRELATED ...
Page 15
... funds. In a typical transaction, a tax-exempt organization would borrow money to acquire real property, lease the property to the seller under a long-term lease, and service the loan with tax-free rental income from 153 See § 1.6, text ...
... funds. In a typical transaction, a tax-exempt organization would borrow money to acquire real property, lease the property to the seller under a long-term lease, and service the loan with tax-free rental income from 153 See § 1.6, text ...
Contents
| 1 | |
| 21 | |
Chapter 3 Modifications | 51 |
Chapter 4 Exceptions | 83 |
Chapter 5 Unrelated DebtFinanced Income Rules | 103 |
Chapter 6 Special Rules | 127 |
Chapter 7 Commercial Activities | 163 |
Chapter 8 Use of Separate Entities | 191 |
Chapter 11 Reporting Requirements | 301 |
APPENDIX A Sources of Law | 331 |
APPENDIX B Internal Revenue Code Section | 339 |
APPENDIX C Glossary | 343 |
APPENDIX D | 345 |
APPENDIX E | 351 |
APPENDIX F | 355 |
Index | 379 |
Chapter 9 Contemporary Applications of the Unrelated Business Rules | 223 |
Chapter 10 Unrelated Business and the Internet | 275 |
Other editions - View all
The Tax Law of Unrelated Business for Nonprofit Organizations Bruce R. Hopkins No preview available - 2009 |
The Tax Law of Unrelated Business for Nonprofit Organizations Bruce R. Hopkins No preview available - 2006 |
The Tax Law of Unrelated Business for Nonprofit Organizations Bruce R. Hopkins No preview available - 2006 |
Common terms and phrases
acquisition indebtedness advertising agency allocable amount apply Ass'n association benefit business income tax business taxable income charitable organization Comm’r commerciality doctrine computing conduct constitute corporation costs court credit counseling debt-financed property deduction described in IRC determined educational employees entity example exclusion exempt function exempt organization exempt purposes expenses for-profit fundraising funds gross income hospital interest Internet IRS ruled joint venture lease limited liability company nonexempt operation orga organiza organization's exempt Organizations described partnership passive income payment percent Priv private letter rulings profit qualified real property regularly carried related business rent revenue royalty Schedule sharecrop social club sponsorship subsidiary substantially related tax-exempt organization taxation Tech tion trade or business trade show United unrelated business activity unrelated business income unrelated business rules unrelated business taxable unrelated debt-financed income unrelated income unrelated trade
Popular passages
Page 336 - Alaska, Arizona, California, Colorado, Hawaii, Idaho, Kansas, Montana, Nevada, New Mexico, Oklahoma, Oregon, Utah, Washington, and Wyoming Georgia, North Carolina, South Carolina, Virginia, and West Virginia.
Page 75 - In the case of a college, university, or hospital, there shall be excluded all income derived from research performed for any person, and all deductions directly connected with such income. (9) In the case of an organization operated primarily for purposes of carrying on fundamental research the results of which are freely available to the general public...
Page 25 - Individual exhibitors; its purpose is the promotion and stimulation of Interest In, and demand for, the Industry's products In general, and it is conducted In a manner reasonably calculated to achieve that purpose. The stimulation of demand for the Industry's products In general is one of the purposes for which exemption is granted O.
Page 18 - An organization may meet the requirements of section 501 (c) (3) although it operates a trade or business as a substantial part of its activities, if the operation of such trade or business is in furtherance of the organization's exempt purpose or purposes and if the organization is not organized or operated for the primary purpose of carrying on an unrelated trade or business, as defined in section 513.
Page 65 - Payments for the use or occupancy of rooms or other space where services are also rendered to the occupant, such as for the use or occupancy of rooms or other quarters in hotels, boarding houses, or apartment houses furnishing hotel services, or in tourist camps or tourist homes, motor courts or motels...
Page 34 - Identity as a trade or business merely because It Is carried on within a larger aggregate of similar activities or within a larger complex of other endeavors which mav.
Page 70 - ... (ii) if the determination of the amount of such rent depends in whole or in part on the income or profits derived by any person from the property leased (other than an amount based on a fixed percentage or percentages of receipts or sales).
Page 23 - For purposes of this section, the term "trade or business" includes any activity which is carried on for the production of income from the sale of goods or the performance of services.
Page 343 - Thus its activities should be directed to the improvement of business conditions of one or more lines of business as distinguished from the performance of particular services for individual persons.
References to this book
Nonprofit Resources: A Companion to Nonprofit Governance Victor Futter,Lisa Runquist Limited preview - 2007 |