Tax Planning and Compliance for Tax-Exempt Organizations, Fifth Edition 2019 Cumulative Supplement, 5th Edition
by Jody Blazek
CHAPTER 10Instrumentalities of Government and Title‐Holding Organizations
§ 10.2 Governmental Units
p. 207, second set of bullets, second item. Replace but at least one with all and replace applies with apply.
p. 207. Add to footnote 3:
See also Priv. Ltr. Rul. LR 201714001 in which income of taxpayer established by county to combat community deterioration was also excludable from gross income under Code Sec. 115(1) where income was derived from taxpayer's performance of essential governmental functions and held and used for the benefit of state, county, and other state political subdivisions. Also, because the taxpayer was instrumentality for IRC § 170(c)(1) purposes, contributions to it were deductible to the extent allowed under IRC § 170.
p. 208. Add after third bullet:
A charter school that operates independently from the state or local municipally controlled school board, in a case considering exemption from the Federal Insurance Contributions Act, was found not to qualify as an instrumentality of the state. The fact that its activities were similar to those of a government‐run local school did not offset the fact that the charter school was not controlled by the state.
p. 208. Add new bullet before last bullet:
Income from trust created by state political subdivision to receive net proceeds from sale of assets ...