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Joint Ventures Involving Tax-Exempt Organizations, 4th Edition
book

Joint Ventures Involving Tax-Exempt Organizations, 4th Edition

by Michael I. Sanders
December 2021
Intermediate to advanced content levelIntermediate to advanced
352 pages
11h 15m
English
Wiley
Content preview from Joint Ventures Involving Tax-Exempt Organizations, 4th Edition

CHAPTER 17International Joint Ventures

  1. § 17.5 General Grantmaking Rules (Revised)
  2. § 17.11 Application of Foreign Tax Treaties

§ 17.5 GENERAL GRANTMAKING RULES (REVISED)

p. 1262. Insert the following new subsection (c) following subsection (b):

(c) Final Foreign Grantmaking Regulations

In September 2015, Treasury published final regulations for private foundations that participate in foreign grantmaking, which continue to permit a private foundation to make a good-faith determination that a prospective foreign grantee is the equivalent of a qualifying charitable organization. The final regulations redefine the IRS-favored approach to making such a determination.

The regulations state that a determination based solely on a “grantee” affidavit is no longer ordinarily considered a good-faith determination. Under the final regulations, a determination will be considered a good-faith determination only if it is based on an opinion from a qualified tax practitioner. Qualified tax practitioners include attorneys, certified public accountants, and enrolled agents, who are subject to the requirements of Circular 230. The change has been made to ensure that equivalency determinations will be based on opinions of persons likely to have a sufficient understanding of the U.S. tax law on charities.

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Joint Ventures Involving Tax-Exempt Organizations, 4th Edition

Joint Ventures Involving Tax-Exempt Organizations, 4th Edition

Michael I. Sanders

Publisher Resources

ISBN: 9781119845607Purchase Link