512(b)(13), the parent exempt organization
is subject to UBTI.
ASAE argued that the IRS should not treat the provision of an Internet link from an exempt organization
to a corporate sponsor's Web site as a taxable event.
Schoenfeld, who has had major responsibility for exempt organization
issues at the Internal Revenue Service (IRS) for more than 15 years, will join Price Waterhouse LLP's Washington National Tax Services practice as a director on July 5, 1995, following his retirement from the IRS.
On some state returns, this is accomplished on the line(s) for nonapportionable income, for example, lines 4 and 8 on Wisconsin's 2014 Form 4T, Wisconsin Exempt Organization
Business Franchise or Income Tax Return.
Director of Higher Education at Radius (formerly High Street Partners) and Director of Global Business Compliance at Harvard University, has joined the Higher Education practice as a partner in the firm's Exempt Organization
(EO) Tax Services group.
6) Founders or controlling members of an exempt organization
However, how an exempt organization
computes UBTI for state income tax purposes varies from state to state.
In the second scenario, consider an exempt organization
that owns an office building containing its headquarters that also has parking facilities.
Depending on the degree of involvement of the exempt organization
, there are four types of joint ventures that may come into play:
Currently, the IRS is investigating situations involving the use of tax-exempt bonds to finance health care facilities in order to determine whether the exempt organization
participant furthers private interests impermissibly.
In a letter ruling, the Internal Revenue Service dealt with a tax-exempt organization
that maintained a teaching hospital formed a wholly-owned captive which reinsured an admitted carrier which had provided medical malpractice insurance to the exempt organization
, full-time faculty members, several other hospitals and full-time resident physicians employed by the hospitals.
The Exempt Organization
as Lender or Ground Lessor.