Joint Ventures Involving Tax-Exempt Organizations, 4th Edition

CHAPTER 16Conservation Organizations in Joint Ventures

1. § 16.1 Overview
2. § 16.2 Conservation and Environmental Protection as a Charitable or Educational Purpose: Public and Private Benefit
3. § 16.3 Conservation Gifts and § 170(h) Contributions (Revised)
4. § 16.7 Emerging Issues

§ 16.1 OVERVIEW

pp. 1200–1201. Insert the following to the end of footnote 1:

For the 2013 tax year, the Urban Institute website reports 8,834 organizations classified as “environmental” on the basis of NTEE code classifications, with aggregate gross receipts of $12.2 billion and aggregate total assets of $25.6 billion. The largest organization in the environmental category, in terms of both gross receipts and total assets, is the National Geographic Society, with gross receipts of $686 million and total assets of $1.3 billion for 2013 (http://nccsweb.urban.org/PubApps/showOrgsByCategory.php?close=1&ntee=C) (last visited March 29, 2016).

§ 16.2 CONSERVATION AND ENVIRONMENTAL PROTECTION AS A CHARITABLE OR EDUCATIONAL PURPOSE: PUBLIC AND PRIVATE BENEFIT

(a) IRS Ruling Position

p. 1201. Insert the following to the end of footnote 2:

PLR 201204020 (organization not exempt under § 501(c)(3) where its lake preservation activities were secondary to promoting the social and recreational activities of residents on the lake); PLR 201210044 (organization providing residential solar energy systems to low- and moderate-income families was not exempt because any environmental benefits to the public would be indirect ...