The Tax Law of Private Foundations, 5th Edition

Table of contents

1. Cover
2. Preface
3. Book Citations
4. CHAPTER ONE: Introduction to Private Foundations
   1. § 1.1 PRIVATE FOUNDATIONS: UNIQUE ORGANIZATIONS
   2. § 1.2 DEFINITION OF PRIVATE FOUNDATION
   3. § 1.7 OPERATING FOR CHARITABLE PURPOSES
   4. § 1.9 PRIVATE FOUNDATION SANCTIONS
   5. PRIVATE FOUNDATION LAW SANCTIONS
   6. § 1.10 STATISTICAL PROFILE
   7. NOTES
5. CHAPTER TWO: Starting, Funding, and Governing a Private Foundation
   1. § 2.1 CHOICE OF ORGANIZATIONAL FORM
   2. § 2.5 ACQUIRING RECOGNITION OF TAX-EXEMPT STATUS
   3. § 2.6 SPECIAL REQUIREMENTS FOR CHARITABLE ORGANIZATIONS
   4. § 2.7 WHEN TO REPORT BACK TO THE IRS
   5. NOTES
6. CHAPTER THREE: Types of Private Foundations
   1. § 3.1 PRIVATE OPERATING FOUNDATIONS
   2. § 3.3 CONDUIT FOUNDATIONS
   3. § 3.9 FOREIGN PRIVATE FOUNDATIONS
   4. NOTES
7. CHAPTER FOUR: Disqualified Persons
   1. § 4.1 SUBSTANTIAL CONTRIBUTORS
   2. § 4.2 FOUNDATION MANAGERS
   3. § 4.3 CERTAIN 20 PERCENT OWNERS
   4. § 4.4 FAMILY MEMBERS
8. CHAPTER FIVE: Self-Dealing
   1. § 5.1 PRIVATE INUREMENT DOCTRINE
   2. § 5.2 PRIVATE BENEFIT DOCTRINE
   3. § 5.3 DEFINITION OF SELF-DEALING
   4. § 5.3A EXCESS COMPENSATION TAX
   5. § 5.4 SALE, EXCHANGE, LEASE, OR FURNISHING OF PROPERTY
   6. § 5.5 LOANS AND OTHER EXTENSIONS OF CREDIT
   7. § 5.6 PAYMENT OF COMPENSATION
   8. § 5.8 USES OF INCOME OR ASSETS BY DISQUALIFIED PERSONS
   9. § 5.11 INDIRECT SELF-DEALING
   10. § 5.12 PROPERTY HELD BY FIDUCIARIES
   11. § 5.14 ADDITIONAL EXCEPTIONS
   12. § 5.15 ISSUES ONCE SELF-DEALING OCCURS
   13. NOTES
9. CHAPTER SIX: Mandatory Distributions
   1. § 6.1 DISTRIBUTION REQUIREMENTS—IN GENERAL
   2. § 6.2 ASSETS USED TO CALCULATE MINIMUM INVESTMENT RETURN
   3. § 6.5 QUALIFYING DISTRIBUTIONS
   4. NOTES
10. CHAPTER SEVEN: Excess Business Holdings
    1. § 7.1 GENERAL RULES
    2. § 7.2 PERMITTED AND EXCESS HOLDINGS
    3. § 7.3 FUNCTIONALLY RELATED BUSINESSES
    4. NOTES
11. CHAPTER EIGHT: Jeopardizing Investments
    1. § 8.2 PRUDENT INVESTMENTS
    2. § 8.3 PROGRAM-RELATED INVESTMENTS
    3. NOTE
12. CHAPTER NINE: Taxable Expenditures
    1. § 9.1 LEGISLATIVE ACTIVITIES
    2. § 9.2 POLITICAL CAMPAIGN ACTIVITIES
    3. § 9.3 GRANTS TO INDIVIDUALS
    4. § 9.5A FUNDING OF EMPLOYEE HARDSHIP PROGRAMS
    5. § 9.6 GRANTS TO FOREIGN ORGANIZATIONS
    6. § 9.9 SPENDING FOR NONCHARITABLE PURPOSES
    7. § 9.10A DISTRIBUTIONS TO GROUP EXEMPTION ORGANIZATIONS
    8. § 9.11 EXCISE TAX FOR TAXABLE EXPENDITURES
    9. NOTES
13. CHAPTER TEN: Tax on Investment Income
    1. § 10.1 RATE OF TAX
    2. § 10.3 FORMULA FOR TAXABLE INCOME
    3. § 10.5 FOREIGN FOUNDATIONS
    4. NOTES
14. CHAPTER ELEVEN: Unrelated Business Activity
    1. § 11.2 EXCEPTIONS
    2. § 11.3 RULES SPECIFICALLY APPLICABLE TO PRIVATE FOUNDATIONS
    3. § 11.4 UNRELATED DEBT-FINANCED INCOME RULES
    4. § 11.5 CALCULATING AND REPORTING THE TAX
    5. NOTES
15. CHAPTER TWELVE: Tax Compliance and Administrative Issues
16. CHAPTER THIRTEEN: Termination of Foundation Status
    1. § 13.1 VOLUNTARY TERMINATION
    2. § 13.3 TRANSFER OF ASSETS TO A PUBLIC CHARITY
    3. § 13.4 OPERATION AS A PUBLIC CHARITY
    4. § 13.6 TERMINATION TAX
    5. NOTES
17. CHAPTER FOURTEEN: Charitable Giving Rules
    1. § 14.1 CONCEPT OF GIFT
    2. § 14.2 BASIC RULES
    3. § 14.4 DEDUCTIBILITY OF GIFTS TO FOUNDATIONS
    4. § 14.5 QUALIFIED APPRECIATED STOCK RULE
    5. § 14.9 ADMINISTRATIVE CONSIDERATIONS
    6. NOTES
18. CHAPTER FIFTEEN: Private Foundations and Public Charities
    1. § 15.2 EVOLUTION OF LAW OF PRIVATE FOUNDATIONS
    2. § 15.3 ORGANIZATIONS WITH INHERENTLY PUBLIC ACTIVITY
    3. § 15.4 PUBLICLY SUPPORTED ORGANIZATIONS—DONATIVE ENTITIES
    4. § 15.5 SERVICE PROVIDER ORGANIZATIONS
    5. § 15.7 SUPPORTING ORGANIZATIONS
    6. § 15.8 CHANGE OF PUBLIC CHARITY CATEGORY
    7. § 15.9 NONCHARITABLE SUPPORTED ORGANIZATIONS
    8. NOTES
19. CHAPTER SIXTEEN: Donor-Advised Funds
    1. § 16.1 BASIC DEFINITIONS
    2. § 16.3 TYPES OF DONOR FUNDS
    3. § 16.9 STATUTORY CRITERIA
    4. § 16.12 TAX REGULATIONS
    5. § 16.13 DAF STATISTICAL PORTRAIT
    6. § 16.14 CRITICISMS AND COMMENTARY
    7. NOTES
20. CHAPTER SEVENTEEN: Corporate Foundations
    1. § 17.3A PRIVATE BENEFIT DOCTRINE
    2. § 17.5 SELF-DEALING RULES
    3. § 17.6 OTHER PRIVATE FOUNDATIONS RULES
    4. NOTES
21. Table of Cases
22. Table of IRS Revenue Rulings and Revenue Procedures
23. Table of IRS Private Determinations Cited in Text
24. Table of IRS Private Letter Rulings, Technical Advice Memoranda, and General Counsel Memoranda
25. About the Author
26. About the Online Resources
27. Cumulative Index
28. End User License Agreement