SmartSellTM - The New Way to Sell Online

We won't be beaten by anyone. Guaranteed

The Tax Law of Private Foundations
By

Rating

Product Description
Product Details

Table of Contents

Preface xiii Book Citations xix 1 Introduction to Private Foundations 1 1.1 Private Foundations: Unique Organizations 1 1.2 Definition of Private Foundation 4 1.3 Background 5 1.4 Private Foundation Law Primer 8 1.5 Foundations in Overall Exempt Organizations Context 15 1.6 Definition of Charity 16 1.7 Operating for Charitable Purposes 17 1.8 Organizational Rules 21 1.9 Private Foundation Sanctions 24 1.10 Statistical Profile 28 2 Starting, Funding, and Governing a Private Foundation 29 2.1 Choice of Organizational Form 30 2.2 Funding a Foundation 31 2.3 Estate Planning Principles 33 2.4 Foundations and Planned Giving 34 2.5 Acquiring Recognition of Tax-Exempt Status 39 2.6 Special Requirements for Charitable Organizations 61 2.7 When to Report Back to the IRS 63 2.8 Governance 71 3 Types of Private Foundations 85 3.1 Private Operating Foundations 85 3.2 Exempt Operating Foundations 107 3.3 Conduit Foundations 107 3.4 Common Fund Foundations 109 3.5 Research and Experimentation Funds 110 3.6 Other Types of Foundations 111 3.7 Nonexempt Charitable Trusts 112 3.8 Split-Interest Trusts 115 3.9 Foreign Private Foundations 117 4 Disqualified Persons 121 4.1 Substantial Contributors 121 4.2 Foundation Managers 124 4.3 Certain 20 Percent Owners 124 4.4 Family Members 127 4.5 Corporations or Partnerships 128 4.6 Trusts or Estates 128 4.7 Private Foundations 129 4.8 Governmental Officials 129 4.9 Termination of Disqualified Person Status 131 5 Self-Dealing 135 5.1 Private Inurement Doctrine 137 5.2 Private Benefit Doctrine 140 5.3 Definition of Self-Dealing 146 5.4 Sale, Exchange, Lease, or Furnishing of Property 150 5.5 Loans and Other Extensions of Credit 163 5.6 Payment of Compensation 167 5.7 Indemnification and Insurance 182 5.8 Uses of Income or Assets by Disqualified Persons 188 5.9 Sharing Space, People, and Expenses 200 5.10 Payments to Government Officials 204 5.11 Indirect Self-Dealing 206 5.12 Property Held by Fiduciaries 212 5.13 Early Terminations of Charitable Remainder Trusts 218 5.14 Additional Exceptions 219 5.15 Issues Once Self-Dealing Occurs 221 6 Mandatory Distributions 235 6.1 Distribution Requirements-In General 235 6.2 Assets Used to Calculate Minimum Investment Return 237 6.3 Measuring Fair Market Value 247 6.4 Distributable Amount 255 6.5 Qualifying Distributions 257 6.6 Distributions to Certain Supporting Organizations 279 6.7 Satisfying the Distribution Test 281 6.8 History of the Mandatory Distribution Requirement 288 7 Excess Business Holdings 293 7.1 General Rules 293 7.2 Permitted and Excess Holdings 300 7.3 Functionally Related Businesses 306 7.4 Philanthropic Businesses 310 7.5 Rules Applicable to Certain Supporting Organizations 310 7.6 Rules Applicable to Donor-Advised Funds 311 7.7 Excise Taxes on Excess Holdings 311 8 Jeopardizing Investments 315 8.1 General Rules 316 8.2 Prudent Investments 321 8.3 Program-Related Investments 331 8.4 Investment Frauds 336 8.5 Excise Taxes for Jeopardizing Investments 340 9 Taxable Expenditures 345 9.1 Legislative Activities 347 9.2 Political Campaign Activities 356 9.3 Grants to Individuals 359 9.4 Grants to Public Charities 380 9.5 Grants to Exempt Operating Foundations 384 9.6 Grants to Foreign Organizations 385 9.7 Expenditure Responsibility 388 9.8 Internet and Private Foundations 399 9.9 Spending for Noncharitable Purposes 404 9.10 Distributions to Certain Supporting Organizations 408 9.11 Excise Tax for Taxable Expenditures 408 10 Tax on Investment Income 415 10.1 Rate of Tax 416 10.2 Reducing Excise Tax 417 10.3 Formula for Taxable Income 422 10.4 Reductions to Gross Investment Income 432 10.5 Foreign Foundations 438 10.6 Exemption from Tax on Investment Income 440 11 Unrelated Business Activity 441 11.1 General Rules 442 11.2 Exceptions 451 11.3 Rules Specifically Applicable to Private Foundations 459 11.4 Unrelated Debt-Financed Income Rules 469 11.5 Calculating and Reporting the Tax 474 12 Tax Compliance and Administrative Issues 479 12.1 Successful Preparation of Form 990-PF 482 12.2 Reports Unique to Private Foundations 501 12.3 Compliance Issues 522 13 Termination of Foundation Status 567 13.1 Voluntary Termination 569 13.2 Involuntary Termination 571 13.3 Transfer of Assets to a Public Charity 572 13.4 Operation as a Public Charity 580 13.5 Mergers, Split-Ups, and Transfers Between Foundations 581 13.6 Termination Tax 595 13.7 Abatement 597 14 Charitable Giving Rules 599 14.1 Concept of Gift 599 14.2 Basic Rules 602 14.3 Gifts of Appreciated Property 604 14.4 Deductibility of Gifts to Foundations 605 14.5 Qualified Appreciated Stock Rule 606 14.6 Deduction Reduction Rules 608 14.7 Special Gift Situations 609 14.8 Planned Giving Revisited 612 14.9 Administrative Considerations 613 15 Private Foundations and Public Charities 621 15.1 Distinctions between Public and Private Charities 622 15.2 Evolution of Law of Private Foundations 624 15.3 Organizations with Inherently Public Activity 626 15.4 Publicly Supported Organizations-Donative Entities 633 15.5 Service Provider Organizations 645 15.6 Comparative Analysis of Categories of Publicly Supported Charities 655 15.7 Supporting Organizations 658 15.8 Change of Public Charity Category 688 15.9 Noncharitable Supported Organizations 689 15.10 Relationships Created for Avoidance Purposes 690 15.11 Reliance by Grantors and Contributors 691 15.12 Other Rules 693 15.13 Public Safety Organizations 694 15.14 Termination of Public Charity Status 694 16 Donor-Advised Funds 697 16.1 Basic Definitions 698 16.2 General Concept of a Gift 699 16.3 Types of Donor Funds 701 16.4 IRS Challenges to Donor Funds 704 16.5 Prohibited Material Restrictions 705 16.6 Department of Justice Position 709 16.7 Public Charity Status of Funds 710 16.8 Interrelationship of Private Foundation Rules 712 16.9 Statutory Criteria 714 16.10 Department of Treasury Study 717 16.11 Congressional Research Service Study 717 16.12 Tax Regulations 721 17 Corporate Foundations 729 17.1 Corporate Foundation Overview 729 17.2 Reasons for Establishment of a Corporate Foundation 731 17.3 Private Inurement Doctrine 731 17.4 Disqualified Persons Rules 732 17.5 Self-Dealing Rules 733 17.6 Other Private Foundations Rules 743 About the Authors 747 About the Online Resources 751 Index 753

About the Author

BRUCE R. HOPKINS practices, with the Bruce R. Hopkins Law Firm, LLC, in the field of tax-exempt organizations, including private foundations, and is widely recognized as one of the country's leading lawyers in the field. JODY BLAZEK is a partner in Blazek & Vetterling, a CPA firm focusing on tax and financial planning for exempt organizations and the individuals who create, fund, and work with them and is recognized as a leading accountant in the field.

Ask a Question About this Product More...
Write your question below:
Look for similar items by category
Home » Books » Business » Nonprofit
Home » Books » Nonfiction » Law » Taxation
People also searched for
How Fishpond Works
Fishpond works with suppliers all over the world to bring you a huge selection of products, really great prices, and delivery included on over 25 million products that we sell. We do our best every day to make Fishpond an awesome place for customers to shop and get what they want — all at the best prices online.
Webmasters, Bloggers & Website Owners
You can earn a 5% commission by selling The Tax Law of Private Foundations (Wiley Nonprofit Authority) on your website. It's easy to get started - we will give you example code. After you're set-up, your website can earn you money while you work, play or even sleep! You should start right now!
Authors / Publishers
Are you the Author or Publisher of a book? Or the manufacturer of one of the millions of products that we sell. You can improve sales and grow your revenue by submitting additional information on this title. The better the information we have about a product, the more we will sell!
Item ships from and is sold by Fishpond.com, Inc.
Back to top