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The Law of Tax-Exempt Organizations + Website, 2017 Cumulative Supplement, 11th Edition

Name: The Law of Tax-Exempt Organizations + Website, 2017 Cumulative Supplement, 11th Edition
Author: Bruce R. Hopkins
ISBN: 9781119345183

by Bruce R. Hopkins

March 2017

Intermediate to advanced

272 pages

6h 41m

English

Wiley

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Cover
Title Page
Copyright
Preface
Chapter One: Definition of and Rationales for Tax-Exempt Organizations
*§ 1.1 Definition of Nonprofit Organization§ 1.2 Definition of Tax-Exempt Organization*§ 1.4 Political Philosophy Rationale
Chapter Two: Overview of Nonprofit Sector and Tax-Exempt Organizations
*§ 2.1 Profile of Nonprofit Sector§ 2.2 Organization of IRS
Chapter Three: Source, Advantages, and Disadvantages of Tax Exemption
*§ 3.2 Recognition of Tax Exemption
Chapter Four: Organizational, Operational, and Related Tests and Doctrines
§ 4.1 Forms of Tax-Exempt Organizations*§ 4.2 Governing Instruments§ 4.5 Operational Test*§ 4.9 State Action Doctrine§ 4.11 Commerciality Doctrine
Chapter Five: Nonprofit Governance
§ 5.7 IRS and Governance
Chapter Six: Concept of Charitable
§ 6.2 Public Policy Doctrine§ 6.3 Collateral Concepts

Chapter Seven: Charitable Organizations
§ 7.4 Provision of Housing§ 7.6 Promotion of Health§ 7.7 Lessening Burdens of Government§ 7.14 Fundraising Organizations§ 7.16 Other Categories of Charity
Chapter Eight: Educational Organizations
*§ 8.1 Federal Tax Law Definition of Educational*§ 8.2 Education Contrasted With Propaganda§ 8.3 Educational Institutions
Chapter Nine: Scientific Organizations
*§ 9.1 Federal Tax Law Definition of Science
Chapter Ten: Religious Organizations
§ 10.1 Constitutional Law Framework*§ 10.2 Federal Tax Law Definition of Religion*§ 10.3 Churches and Similar Institutions§ 10.5 Conventions or Associations of Churches
Chapter Eleven: Other Charitable Organizations
§ 11.9 Endowment Funds
Chapter Twelve: Public Charities and Private Foundations
§ 12.3 Categories of Public Charities§ 12.4 Private Foundation Rules
Chapter Thirteen: Social Welfare Organizations
§ 13.1 Concept of Social Welfare*§ 13.2 Requirement of Community
Chapter Fourteen: Business Leagues and Like Organizations
§ 14.1 Concept of Business League§ 14.2 Disqualifying Activities
Chapter Fifteen: Social Clubs
§ 15.1 Social Clubs in General
Chapter Seventeen: Political Organizations
*§ 17.6 Taxation of Other Exempt Organizations
Chapter Eighteen: Employee Benefit Funds
§ 18.3 Voluntary Employees' Beneficiary Associations
Chapter Nineteen: Other Categories of Tax-Exempt Organizations
*§ 19.6 Cemetery Companies§ 19.19 Qualified Tuition Programs§ 19.20 Able Programs§ 19.22 Governmental and Quasi-Governmental Entities
Chapter Twenty: Private Inurement and Private Benefit
§ 20.1 Concept of Private Inurement*§ 20.3 Definition of Insider*§ 20.4 Compensation Issues§ 20.5 Other Forms of Private Inurement§ 20.12 Private Benefit Doctrine
Chapter Twenty-One: Intermediate Sanctions
*§ 21.9 Rebuttable Presumption of Reasonableness§ 21.10 Excise Tax Regime
Chapter Twenty-Two: Legislative Activities by Tax-Exempt Organizations
*§ 22.3 Lobbying by Charitable Organizations§ 22.6 Legislative Activities of Business Leagues
Chapter Twenty-Three: Political Campaign Activities by Tax-Exempt Organizations
§ 23.2 Prohibition on Charitable Organizations*§ 23.5 Political Activities of Social Welfare Organizations*§ 23.7 Political Activities of Business Leagues
Chapter Twenty-Four: Unrelated Business: Basic Rules
*§ 24.1 Introduction to Unrelated Business Rules*§ 24.2 Definition of Trade or Business*§ 24.3 Definition of Regularly Carried On§ 24.5 Contemporary Applications of Unrelated Business Rules*§ 24.9 Unrelated Debt-Financed Income*§ 24.10 Tax Structure*§ 24.11 Deduction Rules
Chapter Twenty-Five: Unrelated Business: Modifications, Exceptions, and Special Rules
§ 25.1 Modifications§ 25.2 Exceptions§ 25.3 Special Rules
Chapter Twenty-Six: Exemption Recognition and Notice Processes
§ 26.1 Recognition Application Procedure*§ 26.2 Requirements for Charitable Organizations§ 26.3A Notice Requirements for Social Welfare Organizations*§ 26.6 Requirements for Certain Prepaid Tuition Plans*§ 26.9 Rules for Other Organizations*§ 26.10 Group Exemption Rules*§ 26.14 Forfeiture of Tax Exemption*§ 26.14A Modification of Tax Exemption§ 26.15 Constitutional Law Aspects of Process
Chapter Twenty-Seven: Administrative and Litigation Procedures
*§ 27.1 Administrative Procedures Where Recognition Denied§ 27.2 Revocation or Modification of Tax-Exempt Status: Administrative Procedures§ 27.3 Retroactive Revocation of Tax-Exempt Status§ 27.6 Revocation of Tax-Exempt Status: Litigation Procedures§ 27.7 IRS Examination Procedures and Practices*§ 27.10 IRS Disclosure to State Officials
Chapter Twenty-Eight: Operational Requirements
*§ 28.1 Changes in Operations or Form*§ 28.2 Annual Reporting Rules§ 28.3 Annual Information Return*§ 28.4 Notification Requirement§ 28.11 IRS Document Disclosure Rules*§ 28.12 Document Disclosure Obligations of Exempt Organizations§ 28.18 Tax-Exempt Organizations and Tax Shelters§ 28.19 International Grantmaking Requirements
Chapter Twenty-Nine: Tax-Exempt Organizations and Exempt Subsidiaries
§ 29.6 Revenue from Tax-Exempt Subsidiary
Chapter Thirty: Tax-Exempt Organizations and For-Profit Subsidiaries
§ 30.2 Potential of Attribution to Parent§ 30.7 Revenue from For-Profit Subsidiary
Chapter Thirty-Two: Tax-Exempt Organizations: Other Operations and Restructuring
§ 32.7 Single-Member Limited Liability Companies§ 32.10 Conversion from Nonexempt to Exempt Status*§ 32.11 Conversion from One Exempt Status to Another
*Appendix A: Sources of Tax-Exempt Organizations Law
Table of Tax-Exempt Organizations Law Tax Reform Proposals
Cumulative Table of Cases
Cumulative Table of IRS Revenue Rulings
Cumulative Table of IRS Revenue Procedures
Cumulative Table of IRS Private Determinations Cited in Text
Private Letter Rulings, Technical Advice Memoranda, Exemption Denial and Revocation Letters, General Counsel Memoranda, and Chief Counsel Advice MemorandaPrivate Letter Rulings and Technical Advice MemorandaExemption Denial and Revocation LettersGeneral Counsel Memoranda
Cumulative Table of IRS Private Letter Rulings, Technical Advice Memoranda, and Counsel Memoranda
Cumulative Table of Cases Discussed in Bruce R. Hopkins' Nonprofit Counsel
Cumulative Table of IRS Private Determinations Discussed in Bruce R. Hopkins' Nonprofit Counsel
Index
End User License Agreement

Content preview from The Law of Tax-Exempt Organizations + Website, 2017 Cumulative Supplement, 11th Edition

CHAPTER TWENTYPrivate Inurement and Private Benefit

*p. 548, second complete paragraph, fourteenth line. Delete (or entity).

*p. 548, second complete paragraph, sixteenth line. Delete it and insert the organization.

§ 20.1 CONCEPT OF PRIVATE INUREMENT

*p. 550, first complete paragraph, ninth line. Insert general following first the.

p. 550, note 29. Insert following existing text:

Occasionally, the IRS applies the private inurement doctrine, in a case involving a transaction or arrangement with an insider, without making any judgment as to the reasonableness of the matter (e.g., Priv. Ltr. Rul. 201548021).

*§ 20.3 DEFINITION OF INSIDER

*p. 552, second paragraph under heading, sixth line. Delete founders,.

*p. 552, second paragraph under heading, seventh line. Delete certain.

*p. 555, note 71. Move Sound Health Ass'n citation to be first item in footnote.

*§ 20.4 COMPENSATION ISSUES

*(b) Determining Reasonableness of Compensation

*p. 560, note 107, first line. Insert following Also:

H.W. Johnson v. Comm'r, 111 T.C.M. 1418 (2016);

*p. 560, note 109, second line. Delete T.C. Memo. 2015-53 (Mar. 23, 2015) and substitute 109 T.C.M. 1245 (2015).

§ 20.5 OTHER FORMS OF PRIVATE INUREMENT

*p. 564, second paragraph, second line. Delete are and insert involve.

*(e) Equity Distributions

p. 567, carryover paragraph. ...

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