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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 TWENTY-THREE

Political Campaign Activities by Tax-Exempt Organizations

*p. 657, paragraph, second line. Insert affirmatively following not.

*p. 657, paragraph, fourth line. Insert tax following The.

*p. 657, paragraph, sixth line. Insert and state following federal.

§ 23.2 PROHIBITION ON CHARITABLE ORGANIZATIONS

*(a) Scope of the Proscription

*p. 659, second complete paragraph, second line. Insert recognition of following deny.

(b) Participation or Intervention

p. 659, last paragraph. Insert footnote at end of last sentence:

^16.1The use of one or more PARCs was announced in mid-2015, in a memorandum from the Director, Exempt Organizations Division (TEGE-04-0715-0018 (July 17, 2015)), where it was stated that a PARC consists of three General Schedule grade 14 managers, who will receive “appropriate training” and serve as committee members for two years. A PARC is to review and recommend referrals for audit in an “impartial and unbiased manner.” The “inventory volume of political activities referrals” will determine the number of PARCs established and the time commitment required of the members of a PARC. It is not known whether the PACI is continuing by that name and thus whether use of PARCs is an element of an ongoing PACI.

(c) Voter Education Activities

p. 666, note 53. Insert following existing ...

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

by Bruce R. Hopkins

CHAPTER TWENTY-THREE

Political Campaign Activities by Tax-Exempt Organizations