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Tables of Contents for The Law of Tax-Exempt Organizations
Chapter/Section Title
Page #
Page Count
PART ONE: INTRODUCTION TO THE LAW OF TAX-EXEMPT ORGANIZATIONS
Philosophy Underlying and Rationales for Tax-Exempt Organizations
3
2
Nonprofit Organizations
3
1
Tax-Exempt Organizations
3
1
Inherent Tax Rationale
4
1
Freedom of Association
4
1
Overview of Nonprofit Sector and Exempt Organizations
5
3
Statistical Profile of Nonprofit Sector
5
1
Organization of the IRS
5
2
Evolution of the Statutory Scheme
7
1
Charitable Contribution Deduction Rules
7
1
Organizational, Operational, and Similar Tests
8
7
Considerations of Form
8
3
Primary Purpose Test
11
1
Operational Test
11
1
The Exclusively Standard
12
1
The Commensurate Test
12
1
Operations for Profit
12
3
PART TWO: TAX-EXEMPT CHARITABLE ORGANIZATIONS
Scope of Term Charitable
15
1
Federal Tax Law Definition of Charitable
15
1
Public Policy Doctrine and Discrimination
15
1
Some Collateral Concepts
15
1
Charitable Organizations
16
3
Promotion of Health
16
2
Lessening the Burdens of Government
18
1
Advancement of Education or Science
18
1
Educational Organizations
19
1
Education versus Propaganda
19
1
Educational Activity as Commercial Business
19
1
Religious Organizations
20
1
Churches and Similar Institutions
20
1
Religious Orders
20
1
Scientific Organizations
21
1
Concept of Research
21
1
Public Charities and Private Foundations
22
17
Categories of Public Charities
22
1
Donor-Advised Funds (New)
22
17
PART THREE: NONCHARITABLE TAX-EXEMPT ORGANIZATIONS
Social Welfare Organizations
39
1
Concept of Social Welfare
39
1
Comparison with Charitable Organizations
39
1
Associations and Other Business Leagues
40
1
Nonqualifying Business Leagues
40
1
Consequences of Abandonment of Tax-Exempt Status
40
1
Social Clubs
41
1
Discrimination Policies
41
1
Labor, Agricultural, and Horticultural Organizations
42
1
Labor Organizations
42
1
Employee Benefit Funds
43
1
Overview of Employee Benefits Law
43
1
Voluntary Employees' Beneficiary Associations
43
1
Black Lung Benefits Trusts
43
1
Political Organizations
44
2
Political Organizations Defined
44
1
Taxation of Organizations
45
1
Avoiding the Political Organizations Tax
45
1
Other Tax-Exempt Organizations
46
7
Benevolent or Mutual Organizations
46
1
Cemetery Companies
46
1
Homeowners' Associations
47
1
State Tuition Programs
47
1
States, Political Subdivisions, Instrumentalities, Etc.
47
1
Other Tax-Exempt Organizations
48
1
Proposed Exempt Organizations
48
5
PART FOUR: GENERAL EXEMPT ORGANIZATION LAWS
Private Inurement, Private Benefit, and Excess Benefit Transactions
53
16
The Requisite Insider
53
1
Types of Private Inurement
54
4
Incidental Private Inurement
58
1
Private Benefit Doctrine
58
1
Intermediate Sanctions
59
10
Legislative Activities by Exempt Organizations
69
3
Meaning of Legislation
69
1
Lobbying by Charitable Organizations
69
1
Exceptions to Federal Tax Definition of Lobbying by Charitable Organizations
70
1
Lobbying by Associations
70
1
Constitutional Law Considerations
70
2
Political Campaign Activities by Tax-Exempt Organizations
72
2
Political Campaign Activities of Public Charities
72
2
Insurance and Fund-Raising Activities
74
7
Insurance Activities
74
7
Exemption Recognition Process
81
2
Recognition Application Procedure
81
1
Special Requirements for Charitable Organizations
82
1
Integral Part Doctrine
82
1
Operational Considerations
83
12
Changes in Operations or Form
83
1
Annual Reporting Requirements
84
1
Document Availability Requirements
84
6
Disclosure Regarding Certain Information or Services
90
1
Revocation of Exemption: Administrative and Litigation Procedures
90
1
Third-Party Litigation
91
1
The IRS Audit
91
4
PART FIVE: THE COMMERCIALITY DOCTRINE AND UNRELATED BUSINESS INCOME TAXATION
The Commerciality Doctrine
95
1
Origin of Doctrine
95
1
Unrelated Business Activities
96
13
Basic Rationales
96
1
Definition of Trade or Business
96
1
Definition of Regularly Carried On
97
1
Definition of Substantially Related
97
2
Contemporary Applications of the Unrelated Business Rules
99
10
Exceptions to Unrelated Income Taxation
109
7
Modifications
109
5
Exceptions
114
2
Unrelated Income Taxation and Feeder Organizations
116
5
Deduction Rules
116
1
Partnership Rules
116
1
Feeder Organizations
116
5
PART SIX: INTER-ORGANIZATIONAL STRUCTURES AND OPERATIONAL FORMS
Combinations of Tax-Exempt Organizations
121
2
Other Combinations of Tax-Exempt Organizations
121
1
Mergers
122
1
Tax-Exempt Organizations and For-Profit Subsidiaries
123
1
Structural Considerations
123
1
Financial Considerations
123
1
Tax-Exempt Organizations, Partnerships, and Joint Ventures
124
7
Joint Ventures
124
1
Whole Hospital Joint Ventures
124
1
Alternatives to Partnerships
124
7
Organizational and Operational Considerations
131
4
Organizational Considerations
131
1
Conversion from Exempt to Nonexempt Status
131
1
Conversion from Nonexempt Status to Exempt Status
132
1
Recognition of Gain or Loss (New)
132
3
Cumulative Table of Cases
135
28
Cumulative Table of IRS Revenue Rulings and Revenue Procedures
163
12
Cumulative Table of IRS Private Letter Rulings, Technical Advice Memoranda, and General Counsel Memoranda
175
14
Cumulative Table of IRS Private Determinations Cited in Text
189
4
Table of Cases Discussed in The Nonprofit Counsel (New)
193
6
Table of IRS Private Determinations Discussed in The Nonprofit Counsel (New)
199
2
Cumulative Index
201