-
- Abatement, of taxes, §§ 12.4, 21.10
- ABLE programs, § 19.20
- Accountable care organizations, § 7.6(m)
- Accounting periods, changing, § 28.2(a)(vi)
- Achieving a Better Life Experience Act of 2014, § 19.20
- Acquisition indebtedness, § 24.9(c)
- Action organizations, §§ 4.5(d), 22.3(c)(i), 23.1
- Activist organizations, § 23.2(f)
- Activities test, § 4.5(b)
- Adjunct theory, § 7.13(b)
- Administrative procedures
- denial of recognition, § 27.1
- revocation or modification of tax-exempt status, § 27.2
- Advancement organizations
- of education, § 7.8
- of religion, § 7.10
- of science, § 7.9
- Advertising, § 24.5(h)
- Advocacy communications, § 23.9
- Advocacy organizations, § 13.3, Chapters 17, 22, 23
- Affiliated organizations, § 22.2(d)(vii), Chapters 29, 30, 31. See also Subsidiaries
- Affirmative action principles, § 6.2(e)
- Aggregate principle, § 4.5(e)
- Agricultural organizations
- tax exemption of, § 16.2
- and unrelated business rules, § 24.5(f)
- Agricultural Research, Extension, and Teaching Policy Act of 1977, § 7.16
- Agricultural research organizations, §§ 7.16(f), 12.3(a)
- Amateur sports organizations, § 11.2
- American Jobs Protection Act of 2004, § 28.17(h)
- American National Red Cross Governance Modernization Act of 2007, § 5.6(e)
- American Recovery and Reinvestment Act of 2009, §§ 7.6(k), 18.3
- Ancillary joint ventures, § 31.4
- Animals, prevention of cruelty to, § 11.1
- Annual information returns
- ABLE program reports, § 28.4
- and assessments of tax, § 28.2(a)(vi)
- disclosure of, by exempt organizations, § 28.11
- disclosure of, by IRS, § 28.11(a)
- electronic filing of, § 28.8
- exceptions from filing, § 28.2(b)
- filing dates, § 28.2(a)(iv)
- of groups, § 28.2(d)
- IRS database reliance rules, § 28.6
- and IRS examinations, § 27.7(a)(ii)
- and limited liability companies, § 28.2(c)
- notification requirement, § 28.3
- overview of returns, § 28.2(a)
- penalties, § 28.2(a)(v)
- of political organizations, § 28.7
- and tax-exempt status, § 28.5
- Annuities, § 25.1(f)
- Apostolic organizations, § 10.8
- Applicable tax-exempt organizations, § 21.2
- Application for recognition of exemption
- ABLE programs, requirements for, § 26.9
- charitable organizations, requirements for, § 26.2(a)
- completed, § 26.1(c)
- constitutional law aspects of process, § 26.17
- credit counseling organizations, requirements for, § 26.5
- disclosure of, by exempt organizations, § 28.11
- disclosure of, by IRS, § 28.11(a)
- employee benefit organizations, requirements for, § 26.6
- exceptions from filing requirement, § 26.2(b)
- health insurance issuers, requirements for, § 26.7
- information in, § 26.1(a)
- interactive application, § 26.1(f)
- and limited liability companies, § 26.2(c)
- other types of organizations, requirements for, § 26.10
- perjury, penalties for, § 26.1(e)
- prepaid tuition plans, requirements for, § 26.7
- preparation of, § 26.1(b)(iii)
- procedures for, § 26.1
- social welfare organizations, requirements for, § 26.4
- streamlined (Form 1023-EZ), § 26.1(g)
- user fees, § 26.1(d)
- Appraisals, §§ 20.5(c), 32.7(b)
- Articles of organization, §§ 4.2, 4.3, 4.3(c)
- Arts, promotion of, as charitable function, § 7.12
- Asset sales
- as excess benefit, § 21.4(a)
- as private inurement, § 20.5(c)
- as self-dealing, § 12.4(a)
- Assets
- accumulations of, § 30.4
- conditions on transfers, § 11.8(d)
- private operating foundation test for, § 12.1(b)
- sales of, §§ 15.6, 20.5(c)
- Associate member dues, §§ 24.5(e)(iii), 25.2(l)
- Association, freedom of, § 1.7
- Associational test, § 10.3(b)
- Associations. See Business leagues
- Associations of churches, § 10.4
- Assumptions of liability, § 20.5(e)
- Athletic events. See Sports
- Attribution considerations, §§ 30.2, 32.1(d)
- Audits, IRS. See Examination procedures and practices, IRS
- Automatic excess benefit transactions
- and donor-advised funds, § 21.4(e)
- in general, § 21.4(c)
- and supporting organizations, § 21.4(d)
-
- B corporations, § 4.10(d)
- Benefit corporations, § 4.10(e)
- Benefit funds, §§ 15.1(c), 18.2, 18.7
- Benevolent or mutual organizations
- local life insurance associations, § 19.5(a)
- mutual organizations, § 19.5(b)
- Bifurcation, §§ 29.1, 30.1
- Bingo games, § 25.2(h)
- Black Lung Benefits Revenue Act of 1977, § 18.5
- Black lung benefits trusts, § 18.5
- Blocker corporations, § 25.1(n)
- Boards of directors
- compensation of, § 20.4(f)
- composition of, §§ 4.3(d), 5.2
- of credit counseling organizations, § 5.6(h)
- duties of, § 5.3
- fiduciary responsibilities of, § 5.3
- in general, §§ 5.1, 32.1(b)
- independent, § 21.9(a)
- liability of, § 5.4
- and private inurement doctrine, § 20.4(e)
- Boards of trade, § 14.4
- Bonuses, § 20.4(a)
- Boost principle, § 26.13(a)
- Boycotts, § 23.2(g)
- Broadcasting
- by churches, § 10.3(b)
- by educational organizations, § 8.6
- Brownfield sites gain, § 25.1(o)
- Bucketing rule, § 25.5
- Burdens of government, lessening, § 7.7
- Business, definition of, § 24.2
- Business expense deduction disallowance rules, § 22.6(a)
- Business leagues
- business, meaning of, § 14.1(b)
- certification programs, § 14.1(g)
- and charitable subsidiaries, § 29.2(b)
- concept of, § 14.1(a)
- disqualifying activities, § 14.2
- for-profit business activities, § 14.2(b)
- in general, § 14.1(f)
- legislative activities, of, §§ 22.2(c), 22.6
- line-of-business requirement, §§ 14.1(c), 14.2(a)
- membership services, § 14.1(d)
- particular services, performance of, § 14.2(c)
- political activities of, § 23.7
- and private inurement doctrine, §§ 14.2(d), 20.9
- professional organizations, § 14.1(e)
- and unrelated business rules, §§ 14.2(c)(iv), 24.5(e)
- Bylaws, §§ 4.2, 4.3, 4.3(c)
-
- Campaigns, political, §§ 23.2, 23.2(e)
- Candidate, political, definition of, § 23.2(d)
- Capital gains, § 25.1(j)
- Capitalization, of for-profit subsidiaries, § 30.3(a)
- Care of orphans, as charitable function, § 7.16(f)
- Cemetery companies, § 19.6
- Certification programs, §§ 14.1(g), 24.5(q)
- Chambers of commerce, § 14.3
- Charitable, definition of
- common law, § 6.1(b)
- federal tax law, § 6.1(c), Chapter 7
- Charitable activities
- arts, promotion of, § 7.12
- consortia, § 7.13
- credit counseling, § 7.3
- down payment assistance, § 7.5
- education, advancement of, § 7.8
- environmental protection, § 7.16(a)
- fundraising, § 7.14
- health, promotion of, § 7.6
- housing, provision of, § 7.4
- instrumentalities of government, § 7.15
- lessening burdens of government, § 7.7
- local economic development, § 7.16(e)
- other types of, § 7.16(f)
- patriotism, promotion of, § 7.16(b)
- public interest law practice, § 7.16(d)
- relief of distressed, § 7.2
- relief of poor, § 7.1
- religion, advancement of, § 7.10
- science, advancement of, § 7.9
- social welfare, advancement of, § 7.11
- sports, promotion of, § 7.16(c)
- Charitable class, requirement of, § 6.3(a)
- Charitable, concept of
- collateral concepts, § 6.3
- public policy doctrine, § 6.2
- Charitable gift annuities, §§ 24.9(c), 28.15(b)
- Charitable giving, amounts of, § 2.1
- Charitable organizations, Chapter 7
- Charitable organizations listing reliance rules, § 28.7
- Charitable remainder trusts, §§ 19.24, 28.3
- Charitable risk pools, §§ 11.6, 28.14(c)
- Charitable split-dollar insurance plans, § 28.13(d)
- Charity care, § 7.6(a)
- Charity as evolutionary concept, § 6.3(c)
- Charity, other categories of, § 7.16
- Check-the-box regulations
- basic rules, § 4.1(b)(i)
- exempt organization rules, § 4.1(b)(ii)
- Child care organizations, § 8.8
- Choice of entity considerations, § 32.5
- Churches
- associational test, § 10.3(b)
- associations of, § 10.4
- audits of, § 27.7(c)
- conventions of, §§ 10.4, 10.5
- definition of, § 10.3(a)
- examinations of, § 27.7(c)
- exception from annual return filing requirement, § 28.2(b)(i)
- exception from recognition application, § 26.2(b)
- integrated auxiliaries of, § 10.5
- as public charities, § 12.3(a)
- tax exemption of, § 10.3
- Colleges, § 11.9(b). See also Educational institutions; Endowment funds; Schools; Universities
- as public charities, § 12.3(a)
- tax exemption of, § 8.3(a)
- and unrelated business rules, § 24.5(a)
- Combinations of tax-exempt organizations, § 22.2(d)(vii), Chapters 29, 30, 31
- Commensurate test, §§ 4.7, 7.14(b)
- Commercial testing, § 9.2
- Commercial-type insurance
- and tax-exempt status, § 28.14(b)
- and unrelated business rules, § 24.8
- Commerciality, doctrine of
- contemporary perspective on, § 4.9(h)
- and educational institutions, § 8.6
- elements of commerciality, § 4.9(f)
- IRS ruling policy, § 4.9(g)
- origin of, § 4.9(c)
- other applications of doctrine, § 4.9(e)
- publishing and, § 4.9(d)
- rationale for, § 4.9(b)
- summary of, § 4.9(a)
- Commission on Private Philanthropy and Public Needs, §§ 1.4, 2.0 2
- Common fund foundations, § 12.1(e)
- Communal groups, § 10.9
- Community, definition of, § 13.2
- Community associations, §§ 13.2(a), 14.3
- Community benefit standard, § 7.6(a)
- Community foundations, §§ 12.1(f), 12.3(b)(iii)
- Compensation
- of boards of directors, § 20.4(f)
- bonuses, § 20.4(a)
- definition of, § 20.4(a)
- multiple payors of, § 20.4(d)
- reasonableness of, § 20.4(b)
- Competition and unrelated business rules, § 24.2(c)
- Compliance checks, § 27.8
- Condominium management associations, § 13.2(a)
- Conduit foundations, § 12.1(d)
- Conflict-of-interest policies, §§ 5.7(f)(iv), 28.3(e)
- Consortia, § 7.13
- Constitutional law framework
- and exemption recognition process, § 26.15
- free speech, § 10.1(a)(iv)
- Internal Revenue Code provisions (religion), § 10.1(c)
- legislative activities, § 22.9
- for religious organizations, § 10.1(a)
- and tax exemption (for religious organizations), § 10.1(b)
- Continuous improvement, § 2.2(c)
- Contributors, substantial, § 12.2(a)
- Control devices, §§ 12.3(c), 29.1, 30.1(c)
- Controlled entities, §§ 12.3(c), 21.5, 22.3(d)(vii), Chapters 29, 30
- Convenience businesses, § 25.2(b)
- Convenience doctrine, § 25.2(b)
- Conventions, § 25.2(f). See also Trade show activities
- of churches, § 10.4
- on Internet, §§ 24.5(o), 25.2(f)
- Conventions of churches, § 10.4
- Conversions
- from exempt to another exempt status, § 32.8
- from exempt to nonexempt status, federal tax law, § 32.6(b)
- from exempt to nonexempt status, state law, § 32.6(a)
- from nonexempt to exempt status, federal tax law, § 32.7(b)
- from nonexempt to exempt status, state law, § 32.7(a)
- gain or loss recognition, § 32.7(c)
- Cooperative educational service organizations, § 11.5
- Cooperative hospital service organizations, § 11.4
- Cooperatives, §§ 3.4, 19.24
- Corporate sponsorships, § 24.6
- Corporations, as disqualified persons, § 12.2(e)
- Correction requirements, §§ 12.4, 21.11
- Cost allocation rules, §§ 22.3(d)(ii), 22.6(a), 24.11
- Counterpart requirement, for instrumentalities, § 7.14
- Credit counseling, as exempt function, § 7.3
- Credit counseling organizations
- boards of, § 5.6(h)
- and recognition of exemption, §§ 3.2, 26.4
- as tax-exempt organizations, § 7.3
- Credit unions
- potential taxation of, § 4.11(c)
- tax exemption for, § 19.7
- and unrelated business rules, § 24.5(g)
- Crop operations finance corporations, § 19.10
- Cruelty prevention organizations, § 11.1
- Cy pres doctrine, §§ 6.3(f), 6.3(g)
-
- Data-driven decision-making, § 2.2(c)
- Debt management plans, §§ 7.3, 24.5(p)
- Debt-financed income
- and acquisition indebtedness, § 24.9(c)
- and property, § 24.9(b)
- Declaratory judgment rules, § 27.6(b)
- Deductions
- for lobbying expenses, §§ 22.6(a), 22.6(b)
- and unrelated business income, § 24.11
- Deliberative process privilege, § 28.9(b)
- Depreciation, deduction for, §§ 24.11, 28.16(a)
- Determination letters, IRS, § 26.1(c)
- de Tocqueville, Alexis, § 1.4
- Direct lobbying, § 22.3(b)
- Directors
- authority, scope of, § 5.1(e)
- compensation of, §§ 5.7(f)(ii), 20.4(f)
- conflicts of interest, § 5.7(f)(iv)
- control of, § 5.1(d)
- duties of, § 5.3(b)
- liability of, § 5.4
- nomenclature, § 5.1(a)
- number of, § 5.1(b)
- origins of, § 5.1(c)
- role of, §§ 5.7(f)(i), (v), 20.4(e)
- Disaster relief programs, § 7.2(b)
- Disclosure requirements
- annual information returns, §§ 28.10, 28.11
- applications for recognition of exemption, §§ 28.10, 28.11
- donor information, § 28.1(i)
- fundraising, § 28.13
- information, § 28.12
- IRS, § 28.10
- services, § 28.12
- to state officials, by IRS, § 27.9
- unrelated business income tax returns, § 28.2
- Discrimination
- affirmative action, principles of, § 6.2(e)
- and freedom of association, § 1.7
- gender-based, § 6.2(c)
- other forms of, § 6.2(d)
- racial, § 6.2(b)
- and social clubs, § 4.9(b)
- Disqualified persons
- of donor-advised funds, § 11.8(f)
- of private foundations, § 12.2
- of public charities, § 21.3
- Dissolution clause, § 4.3(b)
- Distressed, relief of, § 7.2
- Document disclosure rules, IRS
- federal tax law rules, § 28.11(a)
- Freedom of Information Act, § 28.11(b)
- Domestic fraternal societies, § 19.4(b)
- Donative publicly supported charities, § 12.3(b)(i)
- Donor-advised funds
- automatic excess benefit transactions and, § 21.4(e)
- basics of law, § 11.8(a)
- contributions to, § 11.8(b)
- disqualified persons of, § 11.8(b)
- excess business holdings rules and, § 11.8(b)
- sponsoring organization, definition of, § 11.8(b)
- statutory criteria, § 11.8(b)
- taxable distributions, § 11.8(b)
- Donor-directed funds, § 11.8(a)
- Down payment assistance organizations, § 7.5
- Dual use rule, § 24.4(d)
- Dual-status entities, § 7.6(b)(viii)
-
- Ecclesiastical abstention doctrine, § 10.3(c)
- Economic development, § 7.15(e)
- Education, advancement of, as charitable function, § 7.8
- Educational, definition of, §§ 8.1, 8.2
- Educational activity
- as commercial business, § 8.6
- as private benefit function, § 8.7
- Educational institutions
- colleges, § 8.3(a)
- endowment funds, § 11.9(b)
- museums, § 8.3(b)
- as public charities, § 12.3(a)
- schools, § 8.3(a)
- universities, § 8.3(a)
- and unrelated business rules, § 24.5(a)
- tax exemption for, Chapter 8
- Educational organizations, Chapter 8
- Electronic filing requirement
- in general, § 28.9(b)
- Modernized e-File system, § 28.9(a)
- waivers, § 28.9(c)
- Embezzlements, and private inurement doctrine, § 20.5(k)
- Employee benefit organizations
- black lung benefits trusts, § 18.5
- compensation in general, § 18.1
- and recognition of exemption, § 26.5
- retirement plan trust funds, § 18.6
- supplemental unemployment benefit trusts, § 18.4
- tax exemption for, Chapter 18
- voluntary employees' beneficiary associations, § 18.3
- welfare benefit plans, § 18.2
- Employee benefits
- in general, § 18.1
- and private inurement, § 20.5(f)
- Employee engagement, § 2.2(c)
- Employee Retirement Income Security Act of 1974, § 18.7
- Employees' associations
- businesses of, § 25.2(d)
- tax exemption of, § 19.3
- Endowment funds
- college and university endowments, § 11.9(b)
- definition of, § 11.9(a)
- Form 990 reporting, § 11.9(c)
- taxation of, § 11.9(b)
- Endowment test, for private operating foundations, § 12.1(b)
- Entertainment activities, § 25.2(e)
- Entity, choice of, § 32.8
- Entity, form of, § 4.1
- Entity leasing rules, § 28.17
- Environmental protection, as charitable function, § 7.16(a)
- E-Postcard, § 26.1(h)
- Equity distributions, § 20.5(d)
- Establishment clause, of Constitution, § 10.1(a)(ii)
- Estates, as disqualified persons, § 12.2(g)
- Examination procedures and practices, IRS, § 27.7
- and churches, § 27.7(c)
- coping with, § 27.7(a)(iv)
- correlation with filing requirement, § 27.7(a)(iii)
- in general, §§ 27.7(a), 27.7(a)(i)
- guidelines for, IRS, § 27.7(b)
- types of examinations, § 27.7(a)(ii)
- Exceptions (unrelated business rules)
- associate member dues, §§ 24.5(e)(iii), 25.2(l)
- convenience businesses, § 25.2(b)
- employees' associations, businesses of, § 25.2(d)
- entertainment activities, § 25.2(e)
- gambling, § 25.2(h)
- gift items, sale of, § 25.2(c)
- hospital services, § 25.2(g)
- low-cost articles, § 25.2(j)
- mailing lists, § 25.2(k)
- pole rentals, § 25.2(i)
- small business corporations rules, § 25.2(m)
- trade shows, § 25.2(f)
- volunteer-conducted businesses, § 25.2(a)
- Excess benefit transactions. See Intermediate sanctions
- Excess business holdings rules, §§ 11.8(e), 12.3(c), 12.4(c)
- Excessive compensation
- as excess benefit, § 21.4(a)
- as private inurement, § 20.4
- as self-dealing, § 12.4(a)
- Excise taxes
- abatement of, §§ 12.4, 21.10
- on excess business holdings, § 12.4(c)
- on insurance schemes, § 28.13(c)
- on investment income, § 12.4(f)
- on jeopardizing investments, § 12.4(d)
- on lobbying expenditures, §§ 22.3(d)(iii), 22.4
- on political expenditures, § 23.3
- on self-dealing, § 12.4(a)
- on taxable expenditures, § 12.4(e)
- on tax shelter involvement, § 28.18(f)
- on undistributed income, § 12.4(b)
- Exclusively standard, §§ 4.4, 4.6
- Executive compensation, tax on, § 20.5
- Exempt function (political activities), §§ 17.3, 23.9
- Exempt function revenue. See Unrelated business
- Exempt operating foundations, § 12.1(c)
- Exempt organizations. See Tax-exempt organizations
- Exemption. See Tax exemption
- Exempt Organizations Division, §§ 2.2(b), 2.3, 26.1(j)
- Expenditure test, §§ 22.2(b), 22.3(d)
- Exploitation rule, § 24.4(e)
-
- Facts-and-circumstances test, § 12.3(b)(ii)
- Fair market value, §§ 20.4(b), 20.5
- Family, member of
- private foundation law, § 12.2(d)
- public charity law, § 21.3
- Farmers' cooperatives, § 19.12
- Fast-track case settlement program, § 27.8
- Federal Credit Union Act, § 18.5
- Federal tax law disclosure requirements, § 28.11(a)
- Feeder organizations, § 28.15
- Fees, charging of, §§ 6.3(h), 24.2(e)
- Fifth Amendment, of Constitution, § 27.5(a)
- First Amendment, of Constitution, § 10.1
- Fiscal Year 2016 Omnibus Appropriations Act, § 23.5(a)
- Fiscal Year 2017 Financial Services and General Government Appropriations Act, § 23.5
- Fitness centers, §§ 7.6(i), 24.5(b)(iv)
- Flexible purpose corporations, § 4.10(f)
- Fluid recovery principles, § 6.3(g)
- For the use of transactions, §§ 12.4(a), 21.7
- For-profit organization, defined, § 1.1(a)
- Foreign charitable organizations, §§ 5.6(c), 29.2(e)
- Foreign Relations Authorization Act, Fiscal Years 1988 and 1989, § 26.12
- Foreign source income, § 25.1(n)
- Forfeiture of tax exemption, § 26.14
- Form, changes in, § 28.1(b)
- Form 990, Schedule B, disclosure controversy, § 28.2(a)(i)
- Forms
- 990, §§ 4.3(c), 5.6(g), 11.9(c), 12.3(b)(i), 12.3(b)(ii), 21.4(c), 22.3(c)(iv), 22.3(d)(x), 28.1(a), 28.2, 28.2(a)(i), 28.2(b)(i), 28.7, 28.8(a), 30.3(b)
- 990-BL, § 28.2
- 990-EZ, §§ 28.2, 28.2(a)(ii), 28.3
- 990-N, §§ 26.1(h), 28.2, 28.3
- 990-PF, §§ 28.2, 28.2(a)(iii)
- 990-T, §§ 25.6, 28.2(a)(v), 28.9
- 1023, §§ 3.2(b), 26.1, 26.2
- 1023-EZ, §§ 26.1(g), 28.2
- 1024, §§ 3.2(a), 26.1, 26.5, 26.10
- 1024-A, § 26.4
- 1028, § 26.1
- 1040, § 21.4(c)
- 1065, § 28.2(b)(i)
- 1099, §§ 21.4(c), 28.8(b)
- 1120-H, §§ 19.14, 26.1, 28.2
- 1120-POL, §§ 17.5, 28.2, 28.7(a)
- 4720, §§ 21.14, 28.2(a)(iv), 28.10(a)(ii)
- 5701, § 27.7
- 5768, § 22.3(d)(vi)
- 8832, § 4.1(b)(i)
- 8868, § 28.8(a)
- 8871, § 26.14
- 8872, § 28.7
- 8940, § 3.3
- 14017, § 27.8
- 14018, § 11.9(a)
- i1023, § 26.1(f)
- W-2, §§ 21.4(c), 28.8(b)
- Forms of tax-exempt organizations, § 4.1(a)
- Foundation manager, defined, § 12.2(b)
- Foundations. See Private foundations
- Fragmentation rule, §§ 24.2(f), 29.1
- Fraternal organizations
- domestic fraternal societies, § 19.4(b)
- fraternal beneficiary societies, § 19.4(a)
- Free exercise clause, § 10.1(a)(i)
- Freedom of association doctrine, § 1.7
- Freedom of Information Act, § 28.10(b)
- Friends organizations, § 29.2(e)
- Fringe benefits, value of as unrelated business, § 25.4
- Full and fair exposition test, §§ 8.1, 8.2
- Fundraising
- disclosure requirement, § 28.13
- Fundraising organizations, as charities, § 7.14
-
- Gain, recognition of, § 25.1(j)
- Gambling (gaming), §§ 25.2(h), 28.3(n)
- Gender-based discrimination, § 6.2(c)
- Gift items, sale of, § 25.2(c)
- Governance
- American National Red Cross Governance Modernization Act, § 5.6(e)
- Committee for Purchase proposed best practices, § 5.6(d)
- conflict-of-interest policies, § 5.7(f)(iv)
- credit counseling organizations, boards of, § 5.6(h)
- Form 990, redesigned, § 5.6(g)
- governance philosophy in general, § 5.6(a)
- IRS governance check sheet, § 5.7(e)
- IRS jurisdiction, § 5.7(a)
- IRS officials' speeches, § 5.7(b)
- IRS ruling policy, §§ 5.7(c), 20.12(c)
- IRS training materials, § 5.7(d)
- Panel on Nonprofit Sector good governance principles, § 5.6(f)
- Senate Finance Committee staff paper, § 5.6(b)
- Treasury Department's voluntary best practices, § 5.6(c)
- Governing instruments, § 4.2
- Government
- instrumentalities of, §§ 7.14, 19.22
- lessening burdens of, § 7.7
- officials of, as disqualified persons, § 12.2(i)
- Governmental and quasi-governmental entities
- affiliates of, § 28.2(b)(iii)
- exception from annual return filing requirement, § 28.2(b)(iii)
- income exclusion rule, § 19.22(b)
- intergovernmental immunity, § 19.22(a)
- integral parts of states, § 19.22(c)
- state instrumentalities, § 19.22(d)
- Grassroots lobbying, § 22.3(b)
- Gross investment income fraction, § 12.3(b)(iv)
- Group exemption rules, §§ 26.11, 28.2(d)
-
- Harassment campaign exception, § 28.12(f)
- Health, promotion of, as charitable function, § 7.6
- Health Care and Education Reconciliation Act, § 2.4
- Health care organizations
- as general partners, § 31.2(b)(ii)
- as public charities, § 12.3(a)
- tax exemption of, § 7.6
- and unrelated business rules, § 24.5(b)
- Health insurance exchanges, § 7.6(l)
- Health insurance issuers
- and recognition of exemption, § 26.6
- tax exemption for, § 19.18
- Health maintenance organizations, § 7.6(f)
- High-risk individuals' health care coverage organizations, § 19.15
- Homeowners' associations, § 19.14
- Homes for aged, § 7.6(e)
- Horticultural organizations, § 16.3
- Hospital clinical departments and funds, § 7.6(b)
- Hospitals
- additional statutory requirements for, § 7.6(b)
- clinical departments of, § 7.6(c)
- consortia of, § 7.13
- cooperative service organizations of, § 11.4
- in general, § 7.6(a)
- services to small, § 25.2(g)
- tax exemption of, §§ 7.6(a), 7.6(b)
- and unrelated business rules, § 24.5(b)
- Housing, provision of as charitable function, §§ 7.4, 31.5
- Housing and Economic Recovery Act of 2008, § 7.5
-
- Illegal activities, § 6.3(i)
- Illegal payments, § 20.4(h)
- Immigration and Nationality Act, § 26.12
- Income test for private operating foundations, § 12.1(b)
- Independent investor test, § 20.4(b)
- Indian Reorganization Act of 1934, § 19.23
- Individuals, instruction of, as education, § 8.4
- Information, disclosure of, § 28.12
- Inherent tax rationale, § 1.5
- Initial contract exception, § 21.8
- Insider, definition of, § 20.3
- Institutions, § 12.3(a)
- Instruction
- formal, § 8.3
- of individuals, § 8.4
- of public, § 8.5
- Instrumentalities
- of government, § 7.15
- of United States, § 19.1
- Instrumentality rule, § 6.3(b)
- Insubstantial, definition of, §§ 4.4, 22.3(c), 24.1
- Insurance
- business leagues, programs of, § 24.5(e)(ii)
- charitable split-dollar insurance plans, § 28.14(c)
- commercial-type insurance rules, § 28.14(b)
- excise taxes for participation in, § 28.14(c)
- and intermediate sanctions rules § 21.13
- provision of, as exempt function, § 28.14(a)
- Insurance companies and associations, § 19.9
- Integral part doctrine
- affiliated organizations, § 26.15(a)
- divisions, § 26.15(b)
- Integrated auxiliaries of churches, § 10.5
- Integrated delivery systems, § 7.6(g)
- Interest, § 25.1(c)
- Interest rate swap agreements, § 25.1(i)
- Intergovernmental immunity doctrine, § 19.22(a)
- Intermediaries, § 21.6
- Intermediate sanctions
- automatic excess benefit transactions and donor-advised funds, § 21.4(e)
- automatic excess benefit transactions, in general, § 21.4(c)
- automatic excess benefit transactions and supporting organizations, § 21.4(d)
- concept of, § 21.1
- controlled entities, § 21.5
- correction requirement, § 21.11
- disqualified persons, § 21.3
- excise tax regime, § 21.10
- for the use of transactions, § 21.7
- indemnification, § 21.13
- initial contract exception, § 21.8
- insurance, § 21.13
- intermediaries, § 21.6
- knowing, definition of, § 21.12(b)
- occurrence, definition of, § 21.12(e)
- participation, definition of, § 21.12(a)
- and private inurement doctrine, § 21.16
- professional advice, reliance on, § 21.12(c)
- rebuttable presumption of reasonableness, § 21.9
- return for payment of tax, § 21.14
- revenue-sharing arrangements, § 21.4(b)
- scholarships and similar grants, § 21.4(f)
- and statute of limitations, § 21.15
- tax regime, § 21.10
- tax-exempt organizations involved, § 21.2
- transactions involved, § 21.4
- willful, definition of, § 21.12(d)
- Internal Revenue Service
- agency jurisdiction, § 5.7(a)
- audit guidelines, §§ 27.6(a), 27.6(b)
- and church audits, § 27.6(c)
- compliance checks, § 27.7
- disclosures to state officials, § 27.9
- document disclosure rules, § 28.11
- examination procedures and practices, § 27.6
- fast-track case settlement program, § 27.8
- in general, § 2.2(a)
- officials' governance speeches, § 5.7(b)
- organization of, § 2.2
- reorganization of, § 2.2(a)
- ruling policy as to governance, § 5.7(c)
- state officials, disclosure to, § 27.8
- Tax Exempt and Government Entities Division, §§ 2.2(b), 27.6(a)(i), 27.8
- Internal Revenue Service Restructuring and Reform Act of 1998, § 2.2(a)
- International grantmaking requirements, § 5.6(c)
- Internet communications
- documents, disclosure of, § 28.11
- legislation, attempts to influence, § 22.8
- political campaign activities, § 23.10
- as unrelated business, § 24.5(o)
- Inure, definition of, § 20.1
- Investments, jeopardizing, § 12.4(d)
-
- Joint operating agreements, § 24.5(k)
- Joint ventures
- ancillary, § 31.4
- information reporting, § 31.6
- law basics, § 31.1(b)
- law-imposed, § 31.1(c)
- low-income housing ventures, § 31.5
- and private benefit doctrine, § 20.12(b)
- whole entity, § 31.3
-
- Knowledge management, § 2.2(c)
- Knowledge networks (K-Nets), § 2.2(c)
-
- Labor organizations
- tax exemption for, § 16.1
- and unrelated business rules, § 24.5(f)
- Legal system, maintaining confidence in, as charitable function, § 7.15(f)
- Legislation, meaning of, § 22.2
- Legislative activities
- affiliated organizations, § 22.3(d)(viii)
- by business leagues, § 22.6
- by charitable organizations, § 22.3
- constitutional law framework, § 22.9
- election, expenditure test, § 22.3(d)(vi)
- exceptions, §§ 22.3(c)(iii), 22.3(d)(v)
- excess lobbying expenditures, taxes on, §§ 22.3(d)(iii), 22.4
- expenditure test, §§ 22.2(b), 22.3(d)
- Internet communications, § 22.8
- legislation, meaning of, in associations' dues test, § 22.2(c)
- legislation, meaning of, in expenditure test, § 22.2(b)
- legislation, meaning of, in substantial part test, § 22.2(a)
- legislative history, § 22.3(a)
- lobbying, concept of, § 22.3(b)
- by other tax-exempt organizations, § 22.7
- by private foundations, § 12.4(e)
- reporting rules, §§ 22.3(c)(iv), 22.3(d)(x)
- by social welfare organizations, §§ 13.1(a), 22.5
- substantial part test, §§ 22.2(a), 22.3(c)
- tax sanctions, § 22.4
- Lending arrangements
- as excess benefit, § 21.4(a)
- as private inurement, § 20.5(b)
- as self-dealing, § 12.4(a)
- Lessening burdens of government, as charitable function, § 7.7
- Libraries, § 8.3(c)
- Limited liability companies
- and annual return filing requirement, § 28.2(c)
- in general, § 4.1(b)
- multiple-member, § 32.3
- organizational test for, § 4.3(e)
- and recognition of exemption, § 26.2(c)
- single-member, § 32.4
- as tax-exempt organizations, § 19.24
- Line of business, definition of, § 14.1(c)
- Liquidation of subsidiaries, §§ 30.8, 32.10(c)
- Listed transactions, § 28.18(d)
- Literary organizations, § 11.7
- Litigation, as exempt function, § 7.16(d)
- Litigation procedures
- declaratory judgment rules, § 27.6(b)
- in general, § 27.6(a)
- other approaches, § 27.6(c)
- revocation of tax-exempt status, § 27.6
- Lobbying, concept of
- allowable, §§ 22.3(c)(ii), 22.3(d)(iii)
- direct, § 22.3(b)
- grassroots, § 22.3(b)
- Local associations of employees, § 19.3
- Local character, definition of, § 19.5(a)
- Local economic development, as charitable function, § 7.16(e)
- Lodge system, § 19.4(a)
- Look-through rules, §§ 24.9, 31.1
- Low-cost articles, § 25.2(j)
- Low-profit limited liability companies, § 4.10(c)
-
- Mailing lists, § 25.2(k)
- Mandatory distributions
- private foundations, § 12.4(b)
- supporting organizations, § 12.3(c)
- Means-to-end rule, § 6.3(b)
- Medical research organizations, §§ 7.6(d), 12.3(a)
- Member of family, definition of, §§ 12.2(d), 21.3
- Merchandise, sales of, § 24.5(l)
- Mergers, § 32.1
- Methodology test, § 8.2
- Mill, John Stuart, § 1.4
- Mineral royalties, § 25.1(g)
- Minimum investment return, § 12.4(b)
- Ministerial exception, § 10.3(c)
- Mission societies, § 10.6
- Mission statements, § 4.3(c)
- Modification of tax-exempt status, § 27.2
- Modifications rules (unrelated business)
- annuities, § 25.1(f)
- brownfield sites gain, § 25.1(o)
- capital gains, § 25.1(j)
- consideration, § 25.1(e)
- dividends, § 25.1(b)
- electric companies' member income, § 25.1(m)
- foreign source income, § 25.1(n)
- interest, § 25.1(c)
- interest rate swap agreements, § 25.1(i)
- investment income, other, § 25.1(i)
- loan commitment fees, § 25.1(k)
- notational principal contracts, income from, § 25.1(i)
- passive income, in general, § 25.1(a)
- passive rent test, § 25.1(h)(ii)
- religious order rule, § 25.1(p)
- rental income, § 25.1(h)
- research income, § 25.1(l)
- royalties, § 25.1(g)
- securities lending income, § 25.1(d)
- Multifactor test, § 20.4(b)
- Multiparent title-holding corporations, § 19.2(b)
- Multiple-member limited liability companies, § 32.3
- Museums
- as public charities, § 12.3
- tax exemption for, § 8.3(b)
- and unrelated business rules, § 24.5(c)
- Mutual organizations, § 19.5(b)
- Mutual reserve funds, § 19.8
-
- National Railroad Retirement Investment Trust, § 19.17
- Native American tribes, § 19.23
- Neighborhood land rule, § 24.9(b)
- Net earnings, definition of, § 20.2
- Noncash contributions, reporting of, § 28.3(t)
- Noncharitable organizations
- contributions to, § 29.5
- subsidiaries of, § 29.2
- Nonexempt membership organizations, § 19.25
- Nonexempt status, conversion to exempt status from, § 32.10
- Nonprivate foundation status, § 12.3
- notice requirement, §§ 26.3(a), 26.3(b)
- Nonprofit governance
- agency jurisdiction, § 5.7(a)
- IRS and, § 5.7
- Nonprofit governance principles, § 5.6
- Nonprofit organization, definition of, § 1.1(a)
- Nonprofit sector
- in general, § 1.1(b)
- profile of, § 2.1
- Not-for-profit, definition of, § 1.1(a)
- Notice requirements
- political organizations, § 26.14
- private foundations, § 26.3(a)
- public charities, in general, §§ 26.1, 26.2(a)
- public charities, new, § 26.3(b)
- small organizations, § 28.4
- social welfare organizations, § 26.13
-
- Operational test
- action organizations and, § 4.5(d)
- activities tests, § 4.5(b)
- aggregate principle, § 4.5(e)
- in general, § 4.5(a)
- for political organizations, § 17.3
- for supporting organizations, § 12.3(c)
- quantification of activities, § 4.5(c)
- Operations, changes in, § 28.1(a)
- Orchestras, § 8.3(c)
- Organization managers, § 21.3
- Organizational test
- board composition, § 4.3(d)
- dissolution requirements, § 4.3(b)
- in general, § 4.3
- judicial gloss on, § 4.3(c)
- for limited liability companies, § 4.3(e)
- mission statements, § 4.3(c)
- for political organizations, § 17.2
- for private foundations, §§ 4.3, 12.1(g)
- statement of purposes, § 4.3(a)
- for supporting organizations, §§ 4.3, 12.3(c)
- Orphans, care of, § 11.1
-
- Panel on Nonprofit Sector Governance Principles, § 5.6(f)
- Parent-subsidiary relationships
- subsidiaries in general, § 29.1
- supporting organizations, § 12.3(c)
- Partnerships
- as disqualified persons, § 12.2(f)
- general, § 31.1(a)
- law basics, § 31.1(a)
- limited, § 31.1(a)
- public charities in, § 31.2
- subsidiaries in, § 30.5
- as tax-exempt organizations, § 19.24
- and unrelated business rules, § 24.7
- Passive income, in general, § 25.1(a)
- Passive rent rules, § 25.1(h)(ii)
- Patient Protection and Affordable Care Act, §§ 19.18, 26.5(a)
- Patriotism, promotion of, as charitable function, § 7.16(b)
- Peer review organizations, § 7.6(h)
- Pension Protection Act of 2006, §§ 12.3(c), 12.4(c)
- Per se private inurement, § 20.6
- Percentage-based compensation, § 20.4(c)
- Permitted sources, § 12.3(b)(iv)
- Perpetual care trust funds, §§ 19.6, 19.24
- Personal benefit contract, definition of, § 28.15(c)
- Philanthropy, concept of, §§ 1.4, 6.1(b), 12.4(c)
- Physician recruitment programs, § 20.4(a)
- Planetariums, § 8.3(c)
- Pluralism, § 1.4
- Pole rentals, § 25.2(i)
- Political action committees
- in general, § 17.1(a)
- independent, § 17.8
- Political Activities Compliance Initiative, § 23.2(b)
- political campaign expenditures, taxes on, § 23.3
- by private foundations, § 12.4(e)
- prohibition on charitable organizations, § 23.2
- public office, requirement of, § 23.2(f)
- by social welfare organizations, §§ 13.3(b), 23.5
- and tax sanctions, § 23.3
- voter education activities, § 23.2(c)
- Political activities expenditures, tax on, § 23.4
- Political activities referral committees, § 23.2(b)
- Political campaign activities
- and activist organizations, § 23.2(g)
- advocacy communications, § 23.10
- by business leagues, § 23.8
- campaign, requirement of, § 23.2(e)
- candidate, requirement of, § 23.2(d)
- by charitable organizations, § 23.1
- Internet communications, § 23.11
- by labor organizations, § 23.7
- by other tax-exempt organizations, § 23.9
- participation or intervention, scope of, § 23.2(b)
- prohibition on charitable organizations, § 23.2
- “religious liberty” executive order, § 23.5
- voter education activities, § 23.2(c)
- Political organizations
- defined, § 17.1(a)
- document disclosure requirement, § 28.12(h)
- newsletter funds, § 17.1(b)
- notice requirements, § 26.12
- operational test, § 17.3
- organizational test, § 17.2
- and public policy advocacy activities, § 17.4
- reporting requirements, § 28.8
- tax applied to other exempt organizations, § 17.6
- taxation of, §§ 17.5, 17.7
- Political philosophy and tax-exempt organizations, § 1.4
- Political subdivisions, §§ 7.15, 19.22(b)
- Pooled income funds, § 19.24
- Poor, relief of, § 7.1
- Preamble to the Statute of Charitable Uses, § 1.4
- Prepaid tuition plans, § 19.19
- Preparatory time, § 24.3(d)
- Prevention-of-cruelty organizations, § 11.1
- Primary purpose test, §§ 4.4, 24.1
- Private benefit doctrine
- and educational activity, § 8.7
- in general, § 20.13(a)
- and governance, § 5.7(b)
- incidental private benefit, § 20.13(b)
- joint venture law, § 20.13(c)
- perspective on, § 20.13(d)
- Private foundation rules
- annual return filing requirement, § 28.2(a)(iii)
- excess business holdings, § 12.4(c)
- international grantmaking, § 28.19(b)
- investment income, tax on, § 12.4(f)
- jeopardizing investments, § 12.4(d)
- mandatory distributions, § 12.4(b)
- notice requirement, § 26.3(a)
- presumption of status as, § 26.3(a)
- self-dealing, § 12.4(a)
- taxable expenditures, § 12.4(e)
- Private foundation status, recognition of, § 3.3
- Private foundations
- common fund foundations, § 12.1(e)
- conduit foundations, § 12.1(d)
- defined, § 12.1(a)
- as disqualified persons, § 12.2(h)
- exempt operating foundations, § 12.1(c)
- notice requirement, § 26.3(a)
- organizational test, § 12.1(g)
- private operating foundations, § 12.1(b)
- reporting requirement, § 28.2(a)(iii)
- Private inurement doctrine
- actuality of services rendered, § 20.4(g)
- asset sales, § 20.6(c)
- board, role of, § 20.4(e)
- board member compensation, § 20.4(g)
- and business leagues, §§ 14.2(d), 20.10
- business referral operations, § 20.6(j)
- capital improvements, § 20.6(d)
- compensation, meaning of, § 20.4(a)
- compensation, reasonableness of, § 20.4(b)
- concept of, § 20.1
- embezzlements, § 20.6(m)
- employee benefits, § 20.6(g)
- equity distributions, § 20.6(e)
- goods or refreshments, provision of, § 20.6(k)
- illegal payments, § 20.4(h)
- incidental private inurement, § 20.8
- insider, definition of, § 20.3
- and intermediate sanctions rules, § 21.16
- lending arrangements, § 20.6(b)
- liability, assumptions of, § 20.6(f)
- multiple payors, § 20.4(d)
- net earnings, definition of, § 20.2
- and other categories of exempt organizations, § 20.12
- per se private inurement, § 20.7
- percentage-based compensation, § 20.4(c)
- rental arrangements, § 20.6(a)
- retained interests, § 20.6(l)
- services rendered, § 20.6(i)
- and social clubs, § 20.11
- and social welfare organizations, § 20.9
- tax avoidance schemes, § 20.6(h)
- Private operating foundations, § 12.1(b)
- Private use prohibition, § 6.3(e)
- Professional organizations, § 14.1(e)
- Professional sports leagues, § 19.20
- Profit motive, § 24.2(b)
- Program-related investments, §§ 4.10(b), 12.4(d)
- Promotion of health, as charitable function, § 7.6
- Propaganda, §§ 8.2, 22.3(b)
- Property and casualty insurance companies, § 19.9
- Provision of goods or refreshments, as private inurement, § 20.6(k)
- Provision of services, § 24.5(k)
- Proxy tax, § 22.6(c)
- Public, instruction of, as education, § 8.5
- Public charities
- categories of, § 12.3
- community foundations, §§ 12.1(f), 12.3(b)(iii)
- donative publicly supported charities, § 12.3(b)(i)
- and for-profit subsidiaries, § 30.6
- foundations supporting public educational institutions, § 12.3(b)(v)
- as general partners, § 31.2
- institutions, § 12.3(a)
- notice requirement, § 26.3
- public safety testing organizations, § 12.3(d)
- recognition of, § 3.3
- reporting rules, §§ 28.2, 28.3
- retroactive revocation of exemption of, §§ 27.3, 27.4
- service provider publicly supported charities, § 12.3(b)(iv)
- supporting organizations, § 12.3(c)
- Public interest, requirement of (for scientific research), § 9.3
- Public interest law firms, § 7.16(d)
- Public policy advocacy activities, § 17.4
- Public policy doctrine
- and affirmative action principles, § 6.2(e)
- and gender-based discrimination, § 6.2(c)
- in general, § 6.2(a)
- and other forms of discrimination, § 6.2(d)
- and race-based discrimination, § 6.2(b)
- Public safety testing organizations, §§ 11.3, 12.3(d)
- Publicly supported charities, rules for new, § 26.3(b)
- Publishing activities, §§ 4.9(d), 8.6
- Purposes, statement of, § 4.3(a)
-
- Qualified health insurance issuers, § 19.18
- Qualified sponsorship payments, § 24.6
- Qualified tuition programs
- educational institution-sponsored programs, § 19.19(b)
- other rules, § 19.19(c)
- state-sponsored programs, § 19.19(a)
- Quantification of activities, § 4.5(c)
- Quasi-governmental entities, § 19.22
-
- Racial discrimination, § 6.2(b)
- Railroad Retirement Act of 1974, § 19.18
- Rationales for tax exemption, §§ 1.4–1.6
- Real estate boards, § 14.5
- Real estate development activities, § 24.2(h)
- Rebuttable presumption of reasonableness, § 21.9
- Recognition of public charity, private foundation status, § 3.3
- Recognition of tax exemption
- concept of, § 3.2
- procedure for application for, § 26.1
- Recordkeeping requirements, § 28.18
- Redomestications, § 28.1(c)
- Referral committees, § 27.7(a)
- Regional health information organizations, § 7.6(k)
- Regularly carried on requirement, § 24.3
- Relief of distressed, as charitable function, § 7.2
- Relief of poor, as charitable function, § 7.1
- Religion
- advancement of, as charitable function, § 7.10
- definition of, § 10.2(a)
- Religious Freedom Restoration Act, § 10.1(a)(iii)
- Religious orders, § 10.7
- Religious organizations
- abuse of tax exemption, § 10.2(c)
- apostolic organizations, § 10.8
- bases for denial of tax exemption to, § 10.2(b)
- churches, § 10.3
- communal groups, § 10.9
- constitutional law framework, § 10.1
- conventions or associations of churches, § 10.4
- exception from annual return filing requirement, § 28.2(b)(i)
- exemption from recognition requirement, § 26.2(b)
- integrated auxiliaries of churches, § 10.5
- mission societies, § 10.6
- and political campaign activity, § 23.2
- religious orders, § 10.7
- retreat facilities, § 10.10
- tax exemption of, Chapter 10
- Rent, § 25.1(h)
- Rental arrangements
- as excess benefit, § 21.4(a)
- as exempt function, § 25.1(h)(iii)
- as private inurement, § 20.5(a)
- as self-dealing, § 12.4(a)
- Reorganizations, § 32.2
- Reportable transactions, § 28.18(d)
- Research
- concept of, § 9.2
- income from, § 25.1(l)
- Respect for autonomy, principle of, § 10.3(c)
- Retained interests and private inurement, § 20.5(j)
- Retirement plan reversions, § 24.5(m)
- Retirement plan trust funds, § 18.1
- Retreat facilities, § 10.10
- Retroactive recognition of tax-exempt status, §§ 27.3, 27.4
- Revenue Act of 1913, § 1.4
- Revenue-sharing arrangements, § 21.4(b)
- Revocation of tax-exempt status
- in general, § 27.2
- litigation procedures, § 27.6
- statute of limitations matters, § 27.5
- Royalties, § 25.1(g)
- Rulings, IRS, § 26.1(c)
-
- S corporations
- in liquidations, § 32.8(c)
- as tax-exempt organizations, § 19.24
- Same-sex marriage, § 6.2(d)
- Same state rule, § 24.4(c)
- Sarbanes-Oxley Act, § 5.5
- Scholarships, § 7.8
- Schools
- as public charities, § 12.3(a)
- tax exemption of, § 8.3(a)
- and unrelated business rules, § 24.5(a)
- Science
- advancement of, as charitable function, § 7.9
- definition of, § 9.1
- Scientific activities
- as charitable function, § 9.4
- as educational function, § 9.4
- in general, § 9.1
- Scientific organizations, Chapter 9
- Scientific research, § 9.2
- Securities, loans of, § 25.1(d)
- Self-dealing, § 12.4(a)
- Service provider publicly supported charities, § 12.3(b)(iv)
- Services, disclosure of, § 28.13
- Services referral organizations, § 7.6(j)
- Services rendered
- and private inurement, § 20.5(h)
- and unrelated business, § 24.5(k)
- Set-aside rules, § 12.4(b)
- Share-crop leasing, § 24.5(l)
- Shipowners' protection and indemnity associations, § 19.13
- Single-member limited liability companies, § 32.4
- Size and extent test, § 24.4(b)
- Small organizations
- annual information return, § 28.2(a)(iv)
- exception from annual filing requirement, § 28.2(b)(ii)
- exception from exemption recognition requirement, § 26.2(b)
- notification requirement, § 28.3
- Social clubs
- assets, sale of, § 15.6
- functions of, § 15.1(b)
- investment income limitation, § 15.3
- limitations, exceptions to, § 15.4
- and private inurement, § 20.10
- public use limitation, § 15.2
- state action doctrine and, § 4.9(b)
- tax exemption, rationale for, § 15.1(a)
- taxation of, § 15.5
- and unrelated business rules, § 25.3
- Social enterprise, concept of, § 4.10(a)
- Social welfare
- advancement of, as charitable function, § 7.11
- Social welfare organizations
- as advocacy organizations, § 13.4
- business, conduct of, § 13.3
- and charitable subsidiaries, § 29.2(a)
- community, requirement of, §§ 13.1(b), 13.2
- community and condominium associations, § 13.1(a)
- legislative activities of, § 13.4(a)
- members, benefits to, § 13.1(b)
- notice requirements for, § 26.13
- political campaign activities of, § 13.4(b)
- and private inurement doctrine, § 20.8
- social welfare, concept of, § 13.1(a)
- and unrelated business rules, § 24.5(d)
- Sponsoring organization, defined, § 11.8(e)
- Sponsorship payments, § 24.6
- Sports, promotion of, as charitable function, §§ 7.16(c), 11.2
- State action doctrine
- in general, § 4.8(a)
- and other exempt organizations, § 4.8(c)
- and social clubs, § 4.8(b)
- and statutory law, § 4.8(d)
- State instrumentalities, § 19.22(d)
- State officials, IRS disclosure to, § 27.10
- Subsidiaries
- asset accumulations, § 30.4
- attribution to parent, §§ 29.5, 30.2
- capitalization, § 30.3(a)
- charitable organizations as, § 29.2
- of charitable organizations, § 29.3
- compensation considerations, § 30.3(b)
- and contributions, § 29.8
- control element, § 30.1(c)
- of foreign charitable organizations, § 29.2(e)
- for-profit, Chapter 30
- form, choice of, § 30.1(b)
- law basics, §§ 29.1, 30.1
- liquidations of, § 30.7
- other combinations, § 29.4
- in partnerships, §§ 30.5, 31.7
- resource-sharing, § 30.3(c)
- revenue from, tax treatment of, §§ 29.6, 30.6
- tax-exempt, Chapter 29
- Subsidy, tax exemption as, §§ 1.4, 10.1(b)
- Substantial, definitions of, §§ 4.4, 12.3(b)(i), 22.1, 22.3(c)(ii), 24.1
- Substantial contributor, defined, § 12.2(a)
- Substantial part test, §§ 22.2(a), 22.3(c)
- Supplemental unemployment benefit trusts
- tax exemption for, § 18.4
- and unrelated business income rules, § 24.10
- Support, definition of, §§ 12.3(b)(i), 12.3(b)(iv)
- Support test, private operating foundations, § 12.1(b)
- Supporting organizations
- annual reporting requirement of, § 28.2(a)
- attentiveness test, § 12.3(c)
- automatic excess benefit transactions and, § 21.4(d)
- control of, § 12.3(c)
- Department of the Treasury study of, § 12.3(c)
- excess business holdings rules and, § 12.3(c)
- and for-profit subsidiaries, § 30.6(b)
- functions of, § 12.3(c)
- integral part test, § 12.3(c)
- payout requirement, § 12.3(c)
- private foundation distributions to, § 12.3(c)
- responsiveness test, § 12.3(c)
- types of, § 12.3(c)
- Suspension of tax-exempt status, § 26.12
-
- Tax avoidance schemes, as private inurement, §§ 20.5(g), 20.5(h)
- Tax Cuts and Jobs Act, §§ 20.5, 25.4, 25.5, 25.6
- Tax Exempt and Government Entities Division, §§ 2.2(b), 2.2(c), 26.1(h)
- Tax-exempt entity leasing rules, § 28.16
- Tax-exempt organization, defined, § 1.2
- Tax-exempt organizations
- boards of directors of, §§ 5.1–5.4
- conversion from nonexempt to, § 32.10
- definition of, § 1.2
- dissolution of, § 4.3(b)
- employee benefits and, §§ 3.4(e), 5.3(a), Chapter 18
- forms of, § 4.1(a)
- governing instruments of, § 4.2
- law philosophy, § 1.3
- number of, § 2.1
- political philosophy, § 1.4
- purposes of, § 4.3(a)
- subsidiary revenue and, §§ 29.6, 30.7
- and tax shelters, § 28.18(e)
- Tax-exempt status, modification of, § 27.2
- Tax-exempt status, rationale for
- in law, §§ 1.4–1.6
- inherent tax, § 1.5
- overview, § 1.3
- political philosophy, § 1.4
- Tax-exempt status, revocation of
- procedures, administrative, §§ 27.1, 27.2
- procedures, litigation, § 27.5
- retroactive revocation, § 27.3
- statute of limitations matters, § 27.4
- Tax-exempt subsidiaries, revenue from, § 29.6
- Tax exemption
- and annual notice requirement, §§ 26.1, 26.2, 26.10
- and annual return filing requirement, § 28.2
- and filing requirements, § 28.5
- as government subsidy, § 1.4
- charitable trust, no creation of, § 6.3(m)
- contract, no creation of, § 6.3(j)
- conversion of, § 32.11
- forfeiture of, § 26.14
- for groups, § 26.10
- forfeiture of, § 26.16
- IRS examination procedures and practices, § 27.7
- modification of, § 27.2
- private right of action, no creation of, § 6.3(l)
- recognition, denial of, § 27.1
- recognition of, §§ 3.2, 26.1
- recognition application procedure, § 26.1
- retroactive revocation of, § 27.3
- revocation of, administrative procedures, § 27.2
- revocation of, litigation procedures, § 27.5
- revocation or modification of status, § 27.2
- source of, § 3.1
- suspension of, § 26.12
- Tax expenditures, § 1.2
- Taxpayer Advocate Service, §§ 26.1(h), 26.1(j)
- Tax Reform Act of 1969, § 12.0
- Tax Technical Corrections Act, § 11.8(b)
- Taxable expenditures, § 12.4(e)
- Tax shelter rules, § 28.17
- Teachers' retirement funds, § 18.7
- Technology transfers, § 9.5
- Telephone companies, cooperative, § 19.5(b)
- Termination tax, § 12.4
- Terrorism
- assistance to victims of, § 7.2
- suspension of exemption for supporting, § 26.12
- Testing, commercial, § 9.2
- Theaters, § 7.12
- 35-percent-controlled entities, as disqualified persons, §§ 12.2(e)–(g), 21.3
- Threshold notice rule, §§ 26.2(a), 26.3(a)
- Thrift stores, § 25.2(c)
- Title-holding companies
- multiple-parent organizations, § 19.2(b)
- single-parent organizations, § 19.2(a)
- and unrelated business income rules, § 25.3
- Trade show activities, § 25.2(f)
- Travel and tour activities, § 24.5(j)
- Treasury Inspector General for Tax Administration, §§ 2.2(a), 2.2(b), 5.6(b)
- Trusts, as disqualified persons, § 12.2(g)
- Twenty percent owners, definition of, § 12.2(c)
- Two percent threshold, of support, § 12.3(b)(i)
-
- Unions, § 16.1
- United States, instrumentalities of, § 19.1
- Universities, § 11.9(b). See also Colleges; Educational institutions; Endowment funds; Schools; Unrelated business
- contemporary applications of rules, § 24.5
- by educational institutions, § 24.5(a)
- exceptions, § 25.2
- modifications, § 25.1
- as public charities, § 12.3(a)
- rent, § 25.1(h)
- special rules, § 25.3
- tax exemption of, § 8.3(a)
- and unrelated business rules, § 24.5(a)
- Unrelated business income tax deductions
- charitable deduction, § 25.7(b)
- in general, § 25.7(a)
- net operating loss deduction, § 25.7(d)
- specific deduction. § 25.7(c)
- Unrelated business income tax return
- disclosure of, § 28.9
- filing requirement, § 28.9
- Unrelated business law
- advertising, § 24.5(h)
- by agricultural organizations, § 24.5(f)
- “bucketing rule,” § 25.5
- by business leagues, §§ 14.2(c)(iv), 24.5(e)
- commercial-type insurance, §§ 24.8, 28.15(b)
- and commerciality, §§ 24.2(d), 24.4(e)
- competition, factor of, § 24.2(c)
- contemporary application of rules, § 24.5
- corporate sponsorships, § 24.6
- by credit unions, § 24.5(g)
- debt management plans, § 24.5(p)
- deduction rules, § 25.6
- dual use rule, § 24.4(d)
- by educational institutions, § 24.5(a)
- exceptions as to taxation of, § 25.2. See Exceptions (unrelated business rules)
- exploitation rule, § 24.4(e)
- fees, charging of, § 24.2(e)
- fragmentation rule, § 24.2(f)
- fringe benefit rules, § 25.4
- and fundraising, § 24.5(i)
- by health care providers, § 24.5(b)
- income tax return, § 28.10
- Internet communications, § 24.5(o)
- introduction to rules, § 24.1
- investment plus, concept of, § 24.2(j)
- by labor organizations, § 24.5(f)
- merchandise, sales of, §24.5(l)
- modifications as to income from, § 25.1. See Modifications rules (unrelated business)
- by museums, § 24.5(c)
- nonbusiness activities, § 24.2(g)
- occasional sales, § 24.2(i)
- other organizations' exempt functions, § 24.5(g)
- partnership rules, § 24.7
- preparatory time, § 24.3(c)
- profit motive requirement, § 24.2(b)
- real estate development activities, § 24.2(h)
- regularly carried on, definition of, § 24.3
- related, definition of, § 24.4(a)
- related business activities, § 24.4(f)
- retirement plan conversions, § 24.5(n)
- same state rule, § 24.4(c)
- services, provision of, § 24.5(k)
- share-crop leasing, § 24.5(m)
- size and extent test, § 24.4(b)
- by social welfare organizations, § 24.5(d)
- special rules, § 25.3
- substantially related, definition of, § 24.4(a)
- tax planning consulting, § 24.5(i)(v)
- tax structure, § 25.7
- trade or business, definition of, § 24.2(a)
- travel and tour activities, § 24.5(j)
- unrelated business activities, § 24.4(g)
- and unrelated debt-financed income rules, § 24.9
- Unrelated debt-financed income rules
- acquisition indebtedness, § 24.9(c)
- debt-financed property, § 24.9(b)
- in general, § 24.9(a)
- neighborhood land rule, § 24.9(b)
- real property exception, § 24.9(c)
- User fees, § 26.1(d)
-
- Veterans' organizations
- tax exemption for, §§ 13.1(b), 19.11
- and unrelated business rules, § 25.3
- Victims of Terrorism Tax Relief Act, § 7.2(b)
- Voluntary employees' beneficiary associations
- tax exemption for, § 18.3
- and unrelated business rules, § 25.3
- Volunteers, businesses conducted by, § 25.2(a)
- Voter education activities, § 23.2(c)
- Voting power, definition of, § 21.3
-
- Welfare benefit funds, §§ 15.1(c), 18.2
- Whole entity joint ventures, § 31.3
- Widely available exception, § 28.12(e)
- Workers' compensation reinsurance organizations
- insurance corporations, § 19.16(b)
- state-sponsored organizations, § 19.16(a)
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