By Bertrand M., Jr. Harding
Now in its 3rd variation, The Tax legislation of schools and Universities comprises additions and changes akin to a dialogue of recent ideas relating to web fundraising and advertisements, permitting charitable the rest trusts to take a position in a school's endowment, deferred reimbursement preparations, and consequences for conducting convinced tax-shelter transactions.
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Additional resources for The Tax Law of Colleges and Universities (Wiley Nonprofit Law, Finance and Management Series)
Example text
512(b)-1(c)(2)(iii). , Madden v. C. Memo 1997-395 (Aug. 27, 1997), in which the Tax Court held that because a portion of rent received by a museum from renting its auditorium to a for-profit company was derived from the profits earned by the for-profit company under a sublease, the rental income exclusion did not apply. This case also illustrates the point that if a portion of the rent is based on net profits, the entire rent payment is taxable, not just the portion attributable to the net profits.
2d 1025 (4th Cir. 1986); Currie v. C. 185, 199–200 (1969); Verito v. C. 429, 442 (1965); Adnee v. C. 40, 43 (1963); Polachek v. C. 858, 862 (1954). 83 IRC § 512(b)(1). The expenses associated with the production of this income likewise cannot be deducted in making unrelated business income tax computations. 5. 85 IRC § 163; Priv. Ltr. 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.
24, 1996), which held that income derived by a college from the sale of real property through a limited partnership was not taxable as unrelated business income because the limited partnership did not hold the property primarily for sale to customers. , Priv. Ltr. Rul. 9619069 (Feb. 13, 1996); Priv. Ltr. Rul. 200119061 (Feb. 14, 2001). 66 Parklane Residential Sch,, Inc. v. M. (CCH) 988 (1983). tex V2 - 08/30/2007 UNRELATED BUSINESS INCOME depreciation recapture rules may require a portion of the gain to be taxable as ordinary income.