By Bertrand M., Jr. Harding
Now in its 3rd variation, The Tax legislation of schools and Universities contains additions and differences similar to a dialogue of recent principles concerning net fundraising and ads, permitting charitable the rest trusts to take a position in a school's endowment, deferred reimbursement preparations, and consequences for undertaking definite tax-shelter transactions.
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Additional resources for The Tax Law of Colleges and Universities (Wiley Nonprofit Law, Finance and Management Series)
Priv. Ltr. Rul. 200051049 (Sept. 26, 2000), wherein the IRS concluded that the operation by a hospital of a fitness center was a related activity, in part because the membership fees were set at an amount to permit an ‘‘economic cross-section’’ of the community to join. 60 National Collegiate Athletic Ass’n v. 2d 1417 (10th Cir. C. 456 (1989). 61 2002 Exempt Organizations Continuing Professional Education Technical Instruction Program for FY 2002, at 127 (24th ed. 2001). 65 In one case, a school attempted to raise funds by buying and selling 22 different pieces of real property over a two-year period.
Rul. 8123088 (Mar. 12, 1981). 86 Rev. Rul. B. 233. See also Priv. Ltr. Rul. 9743054 (Aug. 1, 1997), in which the IRS ruled that income received by an IRC § 501(c)(3) organization under a charitable gift annuity program is excludable from unrelated business income as interest. , Priv. Ltr. Rul. 200016023 (Jan. 21, 2000), in which the IRS ruled that rental income received by an IRC § 501(c)(3) medical teaching facility under a lease of its excess space capacity to an IRC § 501(c)(3) rehabilitation hospital was not subject to the unrelated business income tax.
C. 1026, 1032 (1951). See also Gruver v. 2d 363, 368 (4th Cir. ’’ 81 Kemon v. C. 1026, 1032–33 (1951). 85 Likewise, in order to be excludable as a dividend, the payment must be a true distribution of corporate profits and not some other type of corporate distribution. 88 A threshold issue that arises in the application of the rental income exception is whether the payment is properly treated as ‘‘rent’’ and is not instead a disguised distribution of profits from a partnership or joint venture 82 Diamond v.