March 2019
Intermediate to advanced
928 pages
35h 55m
English
Content preview from The Law of Tax-Exempt Organizations, 12th Edition
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CHAPTER THIRTYTax-Exempt Organizations and For-Profit Subsidiaries
- § 30.1 For-Profit Subsidiaries in General
- § 30.2 Potential of Attribution to Parent
- § 30.3 Financial Considerations
- § 30.4 Asset Accumulations
- § 30.5 Subsidiaries in Partnerships
- § 30.6 Revenue from For-Profit Subsidiary
- § 30.7 Liquidations
It is common, if not sometimes essential, for a tax-exempt organization to utilize a for-profit subsidiary, usually to house one or more unrelated business activities1 that are too extensive to be operated within the organization without jeopardizing or losing the parent entity's exempt status.
There are at least five other reasons for use of this technique: situations where the management of a tax-exempt organization (1) does not want to report the receipt of unrelated business income and so shifts the generation of it to a separate subsidiary, (2) wants to insulate the assets of the parent exempt organization from potential liability, (3) desires expansion of the sources of revenue or capital, (4) wishes to use a subsidiary in a partnership, and/or (5) simply is enamored with the idea of utilization of a for-profit subsidiary.2 For example, in illustration of the third of these five ...
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