Joint Ventures Involving Tax-Exempt Organizations: 2018 Cumulative Supplement, Fourth Edition

  • 3h 44m
  • Michael I. Sanders
  • John Wiley & Sons (US)
  • 2019

Effective strategies for non-profit entities in a profit-based world

Joint Ventures Involving Tax-Exempt Organizations examines the procedures, rules, and regulations surrounding joint ventures and partnerships, emphasizing tax-exempt status preservation. Revised and updated to align with current 2017 Tax Act, this supplement offers expert interpretation and practical guidance to professionals seeking a complete reference, including an analysis of impact of the “siloing” of the UBIT rules, the new Opportunity Zone Funds which will incentivize investors in designated census tracts, inter alia. Sample documents enable quick reference and demonstrate real-world application of new laws and guidelines. The discussion delves into planning strategies that can be applied to joint ventures and partnerships while maintaining tax-exempt status, and which joint ventures are best suited for a particular organization.

Widely accepted business strategies for profit-based entities, joint ventures, partnerships, and alliances are increasingly being used by nonprofits in need of additional financial support in challenging economic environments. This book provides invaluable guidance to appropriate planning and structuring while complying with tax-exemption guidelines.

  • Identify the most appropriate transactions for nonprofit organizations
  • Recognize potential problems stemming from debt restructuring and asset protection plans
  • Reference charitable organization, partnerships, and joint venture taxation guidelines
  • Understand which joint venture configurations are best suited to tax-exempt organizations

Joint ventures and partnerships are currently employed by a variety of not-for-profit organizations while maintaining their tax-exempt status. Hospitals, research laboratories, colleges and universities, charter and special-needs schools, low-income housing developments, and many others are reaping the benefits of joint venture participation—but without careful planning and accurate interpretation of current laws, these benefits can be erased by loss of tax-exempt status. Joint Ventures Involving Tax-Exempt Organizations provides practical, up-to-date guidance on realizing the full benefits and avoiding the hazards unique to nonprofit organizations.

About the Author

MICHAEL I. SANDERS (Washington DC) is the lead partner of Blank Rome's Washington office's tax group with a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit transactions. Sanders is also an adjunct professor at George Washington University Law Center and Georgetown University Law School teaching Income Taxation of Partnerships and Subchapter S Corporations and Tax Treatment of Charities and Other Non-Profit Organizations, Joint Ventures Involving Tax Exempt Organizations (including healthcare, universities, LIHTC, new markets, conservation organizations, respectively. Previously, Mr. Sanders served as an attorney-advisor to the assistant secretary of tax policy at the Office of Tax Legislative Counsel and as a trial attorney at the U.S. Department of Justice (Attorney General's Honors Program). He was recently honored in 2010 by The George Washington University School of Law for his 35 years of teaching at the law school.

In this Book

  • Introduction—Joint Ventures Involving Exempt Organizations
  • Taxation of Charitable Organizations
  • Taxation of Partnerships and Joint Ventures
  • Overview—Joint Ventures Involving Exempt Organizations
  • Private Benefit, Private Inurement, and Excess Benefit Transactions
  • Engaging in a Joint Venture—The Choices
  • Exempt Organizations as Accommodating Parties in Tax Shelter Transactions
  • The Unrelated Business Income Tax
  • Debt-Financed Income
  • Limitation on Excess Business Holdings
  • Healthcare Entities in Joint Ventures
  • Low-Income Housing, New Markets, Rehabilitation, and other Tax Credit Programs
  • Joint Ventures with Universities
  • Business Leagues Engaged in Joint Ventures
  • Conservation Organizations in Joint Ventures
  • International Joint Ventures
  • Debt Restructuring and Asset Protection Issues