512(b), passive income from either alternative or direct investments generally does not constitute unrelated business taxable income (UBTI) to tax-exempt
entities, this income, even if it is passive, may be classified as UBTI under Sec.
After all, I don't assist clients with creating tax shelters, and I don't deal with tax-exempt
bonds for both projects will be payable from Payments In Lieu Of Taxes or PILOTs, a structure approved by the City Council on April 25, 2006.
In mid May, the Texas Office of the Comptroller sent a letter to Americans United for Separation of Church and State announcing it had granted tax-exempt
status to the Church of Freethought, a Dallas-area congregation.
NABL and other groups, including members of the recycling community, have sought clarification of the no-value test since the mid- 1990s, when the IRS performed a number of audits of borrowers that used tax-exempt
bonds to finance recycling facilities.
Audits of tax-exempt
bonds can create substantial financial exposure to companies.
In both instances the tax-exempt
entity licensed its name to a taxable organization, which used the name to sell a product.
The IRS, in its ``preliminary adverse ruling'' issued Friday, said the bonds did not meet tax-exempt
standards, which means investors face a possible tax liability should the ruling stand.
With use of the 4 percent credit, the opportunity to also use tax-exempt
bond financing remains available.
Bruck: What, if any, are the present challenges to the tax-exempt
status of long-term care not-for-profits?
In March, the IRS issued Announcement 95-25, which contained proposed revenue ruling regarding the impact of certain physician recruitment incentives on the tax-exempt
status of hospitals that recruited physicians for their nonemployee medical staffs or to provide services on behalf of the hospitals.
The amount of tax-exempt
interest reported by individuals has increased steadily since 1987, the first year for which the IRS began collecting data.
265(a)(2) was to stop taxpayers from borrowing funds with tax-deductible interest and using them to invest in tax-exempt
The repayment structure for the tax-exempt
bonds for both stadiums will be submitted to the City Council for approval.
The memo debunks the frequent claims from Falwell and others that the First Amendment bars the IRS from revoking a church's tax-exempt
status for partisan politicking.