By structuring an arrangement whereby the controlled entity makes specified payments to a parent exempt organization
and generates UBTI, the controlled entity will be able to generate a tax deduction while the exempt organization
will offset its UBTI with net operating losses or tax credits.
will now face a tax on corporate sponsorship payments if their agreement with a sponsor provides that they will not offer or sell products that compete with those of the sponsor.
At the IRS, Schoenfeld has provided policy-level advice and guidance on all technical and enforcement matters relating to exempt organizations
He is well-known throughout the higher ed community and joins perhaps the largest focused practice of exempt organization
tax professionals in the U.
If so, the exempt organization
risks its tax exemption if the third party receives any impermissible benefit.
Most states conform to the federal classification of an entity as an exempt organization
Under the statute covering REITs, certain income, termed "impermissible tenant service income," is income that would not be excluded from the UBIT rental exclusion in IRC Section 512(b)(3) had it been received by an exempt organization
Ancillary joint ventures involve a limited portion of the assets or services of an exempt organization
Introduction: Joint Ventures Involving Exempt Organizations
Today, tax exempt organization
experts from PricewaterhouseCoopers will lead a new BNA Tax & Accounting webinar on Form 990 that provides an overview of how that filing process went for some of the largest tax-exempt organizations
and outlines the compliance challenges that these organizations continue to face.
But according to Williams, Business Systems was "left out of the loop" about the added filing requirement, and the impact this new filing requirement would have on closed exempt organization
application cases attempting to post to the BMF.
The revenue ruling (2004-51) discusses whether an exempt organization
that contributes to, and conducts part of its activities through, a limited liability company formed with a for-profit partner continues to qualify for exemption.
The Exempt Organization
Taxation Technical Resource Panel is preparing an Information Letter Request to the Internal Revenue Service containing examples of ancillary joint ventures between tax-exempt organizations
and for-profit investors that would not jeopardize the organization's exempt status.
Significantly increased reporting requirements apply to exempt organization
activities outside the United States.
If not subject to tax on net income derived from business ventures unrelated to its exempt purpose or functions, an exempt organization
would have a financial advantage over a for-profit entity carrying on a competing enterprise.