Law of Tax-Exempt Organizations

PART ONE: INTRODUCTION TO THE LAW OF TAX-EXEMPT ORGANIZATIONS; 1 Philosophy Underlying and Rationales for Tax-Exempt Organizations; 1.2 Tax-Exempt Organizations; 1.4 Political Philosophy Rationale; 1.6 Other Rationales and Reasons for Tax-Exempt Organizations; 2 Overview of Nonprofit Sector and Tax-Exempt Organizations; 2.1 Profile of Nonprofit Sector; 2.3 Organization of the IRS; 2.4 Evolution of the Statutory Scheme; 2.5 Charitable Contribution Deduction Rules; 2.6 Tax-Exempt Organizations and Tax Shelters (New); 4 Organizational, Operational, and Similar Tests; 4.1 Considerations of Form; 4.3 Organizational Test; 4.5 Operational Test; 4.7 The Commensurate Test; 4.8 Boards of Directors; PART TWO: TAX-EXEMPT CHARITABLE ORGANIZATIONS; 5 Scope of Term Charitable; 5.3 The Public Policy Doctrine; 5.5 Collateral Concepts; 6 Charitable Organizations; 6.1 Relief of the Poor; 6.2 Relief of the Distressed; 6.2A Consumer Credit Counseling (New); 6.2B Homeowners' Assistance Programs (New); 6.3 Promotion of Health; 6.11 Other Categories of Charitable Organizations; 7 Educational Organizations; 7.6A Educational Activity as Private Benefit Function (New); 8 Religious Organizations; 8.1 Constitutional Law Framework; 8.2 Federal Tax Law Considerations; 8.3 Churches and Similar Institutions; 8.7 Apostolic Organizations; 9 Scientific Organizations; 9.5 Technology Transfers; 10 Other Charitable Organizations; 10.2 Amateur Sports Organizations; 10.5 Cooperative Educational Service Organizations; 11 Public Charities and Private Foundations; 11.1 Federal Tax Law Definition of Private Foundation; 11.3 Categories of Public Charities; PART THREE: NONCHARITABLE TAX-EXEMPT ORGANIZATIONS; 13 Associations and Other Business Leagues; 13.1 Business Leagues in General; 13.4 Nonqualified Business Leagues; 14 Social Clubs; 14.1 Social Clubs in General; 14.2 Public Use of Facilities; 14.3 Taxation of Social Clubs; 14.4 Sale of Club Assets; 16 Employee Benefit Funds; 16.3 Voluntary Employees' Beneficiary Associations; 17 Political Organizations; 17.1 Political Organizations Defined; 17.2A Public Policy Advocacy Activities (New); 17.4 Avoiding the Political Organizations Tax; 18 Other Tax-Exempt Organizations; 18.5 Benevolent or Mutual Organizations; 18.8 Property and Casualty Insurance Companies; 18.10 Veterans' Organizations; 18.15 Workers' Compensation Reinsurance Organizations; 18.16 Qualified Tuition Programs; 18.17 States, Political Subdivisions, Instrumentalities, and Integral Parts; 18.20 Proposed Exempt Organizations; PART FOUR: GENERAL EXEMPT ORGANIZATION LAWS; 19 Private Inurement, Private Benefit, and Excess Benefit Transactions; 19.4 Types of Private Inurement; 19.10 Private Benefit Doctrine; 19.11 Excess Benefit Transactions; 19.12 Interrelationship of Doctrines; 20 Legislative Activities by Tax-Exempt Organizations; 20.2 Lobbying by Charitable Organizations; 20.3 Measuring Allowable Lobbying by Charitable Organizations; 20.5 Other Aspects of the Expenditure Test; 20.8 Lobbying by Associations; 21 Political Campaign Activities by Tax-Exempt Organizations; 21.1 Political Campaign Activities of Public Charities; 21.2 Political Expenditures by Charitable Organizations and Tax Sanctions; 21.4 Political Activities of Social Welfare Organizations; 21.4A Political Activities of Labor Organizations (New); 21.4B Political Activities of Associations (New); 21.4C Political Activities of Other Exempt Organizations (New); 21.4D Advocacy Communications (New); 22 Insurance and Fundraising Activities; 22.1 Insurance Activities; 23 Exemption Recognition Process; 23.2 Recognition Application Procedure; 23.3 Special Requirements for Charitable Organizations; 23.4 Nonprivate Foundation Status; 23.6 Notice Requirements for Political Organizations; 23.9 Administrative Procedures Where Determination Is Adverse; 24 Operational Considerations; 24.1 Changes in Operations or Form; 24.3 Annual Reporting Requirements; 24.4 Document Availability Requirements; 24.6 Revocation of Exemption: Administrative and Litigation Procedures; 24.6A Suspension of Exemption (New); 24.8 The IRS Audit; PART FIVE: THE COMMERCIALITY DOCTRINE AND UNRELATED BUSINESS INCOME TAXATION; 25 The Commerciality Doctrine; 25.1 Origin of Doctrine; 25.2 Contemporary Perspective on Doctrine; 26 Unrelated Business Activities; 26.1 Introduction; 26.2 Definition of Trade or Business; 26.4 Definition of Substantially Related; 26.5 Contemporary Applications of the Unrelated Business Rules; 27 Exceptions to Unrelated Income Taxation; 27.1 Modifications; 27.2 Exceptions; 28 Unrelated Income Taxation and Feeder Organizations; 28.1 Tax Structure; 28.3 Special Rules; 28.5 Small Business Corporation Rules; 29 Unrelated Debt-Financed Income and Tax-Exempt Entity Leasing Rules; 29.2 Debt-Financed Property; 29.3 Acquisition Indebtedness; 29.5 Tax-Exempt Entity Leasing Rules; PART SIX: INTER-ORGANIZATIONAL STRUCTURES AND OPERATIONAL FORMS; 30 Combinations of Tax-Exempt Organizations; 30.3 Tax-Exempt Subsidiaries of Charitable Organizations; 30.5 Treatment of Contributions and Other Payments; 30.6 Mergers; 30.7 Use of Single-Member Limited Liability Companies; 31 Tax-Exempt Organizations and For-Profit Subsidiaries; 31.1 Structural Considerations; 31.2 Financial Considerations; 31.2A Asset Accumulations (New); 31.5 Effect of For-Profit Subsidiaries on Public Charity Status; 32 Tax-Exempt Organizations, Partnerships, and Joint Ventures; 32.1 Partnerships Basics; 32.2 The Tax Exemption Issue; 32.3 Joint Ventures; 32.4 Whole Hospital Joint Ventures; 32.5 Ancillary Joint Ventures; 32.7 Alternatives to Partnerships; 33 Organizational and Operational Considerations; 33.1 Organizational Considerations; 33.3 Conversion from Exempt to Nonexempt Status; 33.5 Recognition of Gain or Loss; 33.7 Corporate Responsiblity Legislation; 33.8 The "Social Enterprise" Movement (New); Appendix A: Sources of the Law; Appendix B: Internal Revenue Code Sections; Cumulative Table of Cases; Cumulative Table of IRS Revenue Rulings and Revenue Procedures; Cumulative Table of IRS Private Determinations Cited in Text; Cumulative Table of Cases Discussed in Bruce R. Hopkins' Nonprofit Counsel; Cumulative Table of IRS Private Determinations Discussed in Bruce R. Hopkins' Nonprofit Counsel; Cumulative Table of IRS Private Letter Rulings, Technical Advice Memoranda, and General Counsel Memoranda; Index

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• Tributação , taxas e impostos