Table of Contents
Preface ix
Part I Qualifications of Tax-Exempt Organizations 1
Chapter 1 Distinguishing Characteristics of Tax-Exempt Organizations 3
§ 1.8 Developments Responding to COVID-19
Chapter 2 Qualifying Under IRC § 501(c)(3) 11
§ 2.2 Operational Test
Chapter 3 Religious Organizations 19
§ 3.2 Churches
Chapter 4 Charitable Organizations 23
§ 4.1 Relief of the Poor
§ 4.3 Lessening the Burdens of Government
§ 4.5 Advancement of Education and Science
§ 4.6 Promotion of Health
Chapter 5 Educational, Scientific, and Literary Purposes and Prevention of Cruelty to Children and Animals 29
§ 5.1 Educational Purposes
Chapter 6 Civic Leagues and Local Associations of Employees: § 501(c)(4) 31
§ 6.2 Qualifying and Nonqualifying Civic Organizations
Chapter 9 Social Clubs: § 501(c)(7) 35
§ 9.4 Revenue Tests
Chapter 11 Public Charities 37
§ 11.2 “Inherently Public Activity” and Broad Public Support: § 509(a)(1)
§ 11.5 Difference Between § 509(a)(1) and § 509(a)(2)
Part II Standards For Private Foundations 39
Chapter 12 Private Foundations - General Concepts 41
§ 12.4 Termination of Private Foundation Status
Chapter 14 Self-Dealing: IRC § 4941 43
§ 14.2 Sale, Exchange, or Lease of Property
§ 14.5 Transactions That Benefit Disqualified Persons
Chapter 15 Minimum Distribution Requirements: IRC § 4942 45
§ 15.1 Assets Used to Calculate Minimum Investment Return
§ 15.2 Measuring Fair Market Value
§ 15.4 Qualifying Distributions
Chapter 16 Excess Business Holdings and Jeopardizing Investments: IRC §§ 4943 and 4944 51
§ 16.1 Excess Business Holdings
§ 16.2 Jeopardizing Investments
Chapter 17 Taxable Expenditures: IRC § 4945 53
§ 17.3 Grants to Individuals
§ 17.4 Grants to Public Charities
Part III Obtaining and Maintaining Tax-Exempt Status 59
Chapter 18 IRS Filings, Procedures, and Policies 61
§ 18.1 IRS Determination Process
§ 18.2 Annual Filing of Form 990
§ 18.4 Weathering an IRS Examination
Chapter 19 Maintaining Exempt Status 77
§ 19.1 Checklists
Chapter 20 Private Inurement and Intermediate Sanctions 85
§ 20.11 New § 4960 Excise Tax on Excess Compensation
Chapter 21 Unrelated Business Income 89
§ 21.4 Definition of Trade or Business
§ 21.8 Unrelated Activities
§ 21.10 Income Modifications
§ 21.11 Calculating and Minimizing Taxable Income
Chapter 23 Electioneering and Lobbying 95
§ 23.3 Tax on Political Expenditures
Chapter 24 Deductibility and Disclosures 99
§ 24.1 Overview of Deductibility
§ 24.2 The Substantiation and Quid Pro Quo Rules
§ 24.3 Valuing Donor Benefits
Chapter 25 Employment Taxes 105
§ 25.1 Distinctions Between Employees and Independent Contractors
Index 111
