By Michael I. Sanders
During this necessary source, partnerships and joint ventures are sincerely outlined, and the exams utilized by the IRS to judge those relationships are defined. The e-book additionally surveys equipment that nonprofits can use to elevate capital and reports the tips governing nonprofit eligibility for federal housing information. The ebook comprises pattern kinds, numerous footnotes, and diverse citations to case legislation, inner profit Code sections, and different suitable rulings. Written by means of a common lecturer on partnerships and exempt agencies, this worthy advisor is supplemented each year to make sure that subscribers are saved up to date in this always altering topic.
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Extra resources for Joint Ventures Involving Tax-Exempt Organizations (Wiley Nonprofit Law, Finance and Management Series)
6. ” Treasury Regulations will be cited as “Reg. , 1990); Harlan E. Moore Charitable Trust v. United States, 812 F. Supp. D. Ill. 3d 623 (Nov. 3, 1993), acq. in action on decision, 95-3953 (Apr. 14, 1995) (Issues 1 and 2). , 1990); see also §7701 (a)(2). See Chapter 17 for a detailed discussion of limited liability companies. §701; Reg. 701-1. 12 A joint venture is treated as a partnership for federal income tax purposes,13 but unlike a partnership, a joint venture does not entail a continuing relationship among the parties.
D. Tex. 1990) (general partner jointly and severally liable for partnership acts); Betz v. 2d 831 (Alaska 1982) (general partner personally liable on debts even after retirement from partnership). Gen. Couns. Mem. 39,005 (Dec. 17, 1982). See also Uniform Limited Partnership Act, note 54; see also Revised Uniform Limited Partnership Act, note 54. See 1996 CPE Housing Article, Part II, Topic B, Part II6. In certain situations, however, it may be acceptable for the charity to be a non-managing member.
Notwithstanding the recent scrutiny of certain program strategies, conservation organizations, including those determined to be exempt under §501(c)(3) and (c)(4), as well as state and local government agencies, increasingly must rely on joint ventures and similar arrangements to raise needed financial capital and obtain private market technical and transactional expertise to further exempt purposes. This book dedicates a chapter to these unique joint venture arrangements, which pays particular attention to the Senate Finance Committee’s recent investigation of several joint ventures entered into by The Nature Conservancy, one of the most prominent conservation groups operating in the United States.