March 2017
Intermediate to advanced
272 pages
6h 41m
English
book
The Law of Tax-Exempt Organizations + Website, 2017 Cumulative Supplement, 11th Edition
by Bruce R. Hopkins
Content preview from The Law of Tax-Exempt Organizations + Website, 2017 Cumulative Supplement, 11th Edition
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CHAPTER THIRTYTax-Exempt Organizations and For-Profit Subsidiaries
§ 30.2 POTENTIAL OF ATTRIBUTION TO PARENT
p. 972, note 50. Delete appellate court citation and insert 486 Fed. Appx. 655 (6th Cir. 2012).
*p. 973, second paragraph. Insert as second sentence:
Likewise, an exempt university that formed a for-profit subsidiary to conduct online educational programs for adults received a ruling from the IRS holding that the subsidiary is a separate legal entity with its own “activities and management,” having a “real and substantial business purpose,” so that its operations will not be attributed to its parent.60.1
§ 30.7 REVENUE FROM FOR-PROFIT SUBSIDIARY
(d) Temporary Rule
p. 982, second heading. Delete Temporary and substitute Special.
p. 982, last paragraph. Delete first sentence (including footnote) and substitute:
Notwithstanding the foregoing, a special rule applies with respect to certain payments to tax-exempt controlling organizations by their subsidiaries.127
p. 983, carryover paragraph, sixth line. Delete Temporary and insert Special.
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