By Michael I. Sanders
A finished, revised, and accelerated consultant masking tax-exempt enterprises carrying out joint ventures Joint Ventures related to Tax-Exempt companies, Fourth version examines the legal responsibility of, and results to, exempt agencies engaging in joint ventures with for-profit and different tax-exempt entities. This authoritative consultant offers unbridled entry to appropriate IRC provisions, Treasury laws, IRS rulings, and pertinent judicial judgements and legislative advancements that impression exempt firms eager about joint ventures.Features extensive an. Read more...
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Additional resources for Joint ventures involving tax-exempt organizations
Gen. Couns. Mem. 36,293 (May 30, 1975) (IRS prior position effectively overruled by later rulings). 4(a). 4(a). 51 Rev. Rul. B. 6. ,’’ Tax Notes at 829 (Nov. 16, 1998). 2 and Chapter 6. 2. 53 See Gen. Couns. Mem. 39,005 (June 28, 1983). 8 REV. RUL. 58 The IRS guidelines for determining whether a tax-exempt organization jeopardizes its exempt status by participating in a joint venture are contained in Rev. Rul. 60 However, the IRS has stated that any partnership or other joint venture arrangement between a §501(c)(3) organization and one or more for-profit entities requires ‘‘close scrutiny’’ to determine whether the potential conflict between the exempt organization’s duty to operate exclusively for exempt purposes and any duty it 54 Remarks of Marcus Owens, Meeting of the ABA Tax Section (Aug.
The funds may invest in local entities that own projects eligible for LIHTC. These local partnerships (which acquire, construct, own, and manage the low-income housing projects) are commonly referred to as operating or project partnerships/LLCs. Operating entities generally consist of a local tax-exempt organization or its wholly owned for-profit subsidiary, which serves as general partner/ manager or as a manager of an LLC, and an equity fund (or a single corporate investor), which is admitted as a partner or member.
46 See Chapter 13, supra, for new developments in this area. 13 INTRODUCTION: JOINT VENTURES INVOLVING EXEMPT ORGANIZATIONS authority to be used for the recovery and redevelopment of the Gulf Opportunity Zone. Under the recently passed American Taxpayer Relief Act, the program has been extended through 2013. The impact of these joint ventures, NMTC partnerships between exempt CDEs and for-profit investors, has expanded economic investment and revitalization in historically impoverished communities.