- Cover
- List of Exhibits
- Preface
- About the Author
- Acknowledgments
- PART I: Qualifications of Tax-Exempt Organizations
- CHAPTER 1: Distinguishing Characteristics of Tax-Exempt Organizations
- CHAPTER 2: Qualifying Under IRC §501(c)(3)
- CHAPTER 3: Religious Organizations
- CHAPTER 4: Charitable Organizations
- CHAPTER 5: Educational, Scientific, and Literary Purposes and Prevention of Cruelty to Children and Animals
- 5.1 Educational Purposes
- 5.2 Literary Purposes
- 5.3 Scientific Purposes
- 5.4 Testing for Public Safety
- 5.5 Fostering National or International Amateur Sports Competition (But Only If No Part of Its Activities Involves the Provision of Athletic Facilities or Equipment)
- 5.6 Prevention of Cruelty to Children or Animals
- Notes
- CHAPTER 6: Civic Leagues and Local Associations of Employees: §501(c)(4)
- CHAPTER 7: Labor, Agricultural, and Horticultural Organizations: §501(c)(5)
- CHAPTER 8: Business Leagues: §501(c)(6)
- 8.1 Basic Characteristics
- 8.2 Meaning of “Common Business Interest”
- 8.3 Line of Business
- 8.4 Rendering Services for Members
- 8.5 Sources of Revenue
- 8.6 Membership Categories
- 8.7 Member Inurement
- 8.8 Chambers of Commerce and Boards of Trade
- 8.9 Comparison to §501(c)(5)
- 8.10 Recognition of Exempt Status
- 8.11 Formation of a Related Charitable Organization
- 8.12 Disclosures for Lobbying and Nondeductibility
- Notes
- CHAPTER 9: Social Clubs: §501(c)(7)
- CHAPTER 10: Instrumentalities of Government and Title-Holding Corporations
- CHAPTER 11: Public Charities
- 11.1 Distinctions between Public and Private Charities
- 11.2 “Inherently Public Activity” and Broad Public Support: §509(a)(1)
- 11.3 Community Foundations
- 11.4 Service-Providing Organizations: §509(a)(2)
- 11.5 Difference Between §509(a)(1) and §509(a)(2)
- 11.6 Supporting Organizations: §509(a)(3)
- 11.7 Testing for Public Safety: §509(a)(4)
- Notes
- PART II: Standards for Private Foundations
- CHAPTER 12: Private Foundations—General Concepts
- 12.1 Why Private Foundations Are Special
- 12.2 Special Rules Pertaining to Private Foundations
- 12.3 Application of Taxes to Certain Nonexempt Trusts
- 12.4 Termination of Private Foundation Status
- APPENDIX 12-1 Brief Description of Tax Sanctions Applicable to Private Foundations
- Excise Tax on Investment Income—§4940 Tax
- Notes
- CHAPTER 13: Excise Tax Based on Investment Income: IRC §4940
- CHAPTER 14: Self-Dealing: IRC §4941
- 14.1 Definition of Self-Dealing
- 14.2 Sale, Exchange, or Lease of Property
- 14.3 Loans
- 14.4 Compensation
- 14.5 Transactions that Benefit Disqualified Persons
- 14.6 Payments to Government Officials
- 14.7 Sharing Space, People, and Expenses
- 14.8 Indirect Deals
- 14.9 Property Held by Fiduciaries
- 14.10 Issues Once Self-Dealing Occurs
- Notes
- CHAPTER 15: Minimum Distribution Requirements: IRC §4942
- CHAPTER 16: Excess Business Holdings and Jeopardizing Investments: IRC §§4943 and 4944
- CHAPTER 17: Taxable Expenditures: IRC §4945
- 17.1 Lobbying
- 17.2 Voter Registration Drives
- 17.3 Grants to Individuals
- 17.4 Grants to Public Charities
- 17.5 Grants to Foreign Organizations
- 17.6 Expenditure Responsibility Grants
- 17.7 Noncharitable Expenditures
- 17.8 Excise Taxes Payable
- APPENDIX 17–1: Examples of Emergency, Hardship Grant Application, Church and Foreign Equivalency Grants
- Application For Emergency Assistance
- Application for Hardship Assistance Lower Income
- Church Substantiation Form
- Notes
- CHAPTER 12: Private Foundations—General Concepts
- PART III: Obtaining and Maintaining Tax-Exempt Status
- CHAPTER 18: IRS Filings, Procedures, and Policies
- CHAPTER 19: Maintaining Exempt Status
- CHAPTER 20: Private Inurement and Intermediate Sanctions
- 20.1 Defining Inurement
- 20.2 Salaries and Other Compensation
- 20.3 Setting Salary
- 20.4 Housing and Meals
- 20.5 Purchase, Lease, or Sale of Property or Services
- 20.6 Loans and Guarantees
- 20.7 For‐Profit to Nonprofit and Vice Versa
- 20.8 Services Rendered for Individuals
- 20.9 Joint Ventures
- 20.10 Intermediate Sanctions
- Notes
- CHAPTER 21: Unrelated Business Income
- 21.1 IRS Scrutiny of Unrelated Business Income
- 21.2 History of the Unrelated Business Income Tax
- 21.3 Consequences of Receiving UBI
- 21.4 Definition of Trade or Business
- 21.5 What Is Unrelated Business Income?
- 21.6 “Regularly Carried On”
- 21.7 “Substantially Related”
- 21.8 Unrelated Activities
- 21.9 The Exceptions
- 21.10 Income Modifications
- 21.11 Calculating and Minimizing Taxable Income
- 21.12 Debt-Financed Property
- 21.13 Museums
- 21.14 Travel Tours
- 21.15 Publishing
- Notes
- CHAPTER 22: Relationships with Other Organizations and Businesses
- CHAPTER 23: Electioneering and Lobbying
- 23.1 Election Campaign Involvement
- 23.2 Voter Education versus Candidate Promotion
- 23.3 Tax on Political Expenditures
- 23.4 Lobbying Activity of §501(c)(3) Organizations
- 23.5 Permissible Amounts of Lobbying
- 23.6 Lobbying Limits for §501(c)(4), (5), (6), and Other Exempt Organizations
- 23.7 Advocacy and Nonpartisan Analysis
- Notes
- CHAPTER 24: Deductibility and Disclosures
- CHAPTER 25: Employment Taxes
- CHAPTER 26: Mergers, Bankruptcies, and Terminations
- Table of Cases
- Table of IRS Revenue Rulings
- Table of IRS Procedures
- Index
- End User License Agreement
To all the wonderful nonprofit clients, seminar participants, and fellow CPAs and lawyers who serve nonprofits for asking the questions that provide fuel for this book.
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