Michael I. Sanders 
Joint Ventures Involving Tax-Exempt Organizations 

A comprehensive, revised, and expanded guide covering tax-exempt
organizations engaging in joint ventures

Joint Ventures Involving Tax-Exempt Organizations, Fourth
Edition examines the liability of, and consequences to, exempt
organizations participating in joint ventures with for-profit and
other tax-exempt entities. This authoritative guide provides
unbridled access to relevant IRC provisions, Treasury regulations,
IRS rulings, and pertinent judicial decisions and legislative
developments that impact exempt organizations involved in joint
ventures.

* Features in depth analysis of the IRS’s requirements for
structuring joint ventures to protect a nonprofit’s exemption as
well as to minimize UBIT

* Includes sample models, checklists, and numerous citations to
Internal Revenue Code sections, Treasury Regulations, case law, and
IRS rulings

* Presents models, guidelines, and suggestions for structuring
joint ventures and minimizing the risk of audit

* Contains detailed coverage of: new Internal Revenue Code
requirements impacting charitable hospitals including Section
501(r) and related provisions; university ventures, revised Form
990, with a focus on nonprofits engaged in joint ventures; the
IRS’s emphasis on good governance practices; international
activities by nonprofits; and a comprehensive examination of the
New Market Tax Credits and Low Income Housing Tax Credits
arena

Written by a noted expert in the field, Joint Ventures
Involving Tax-Exempt Organizations, Fourth Edition is the most
in-depth discussion of this critical topic.

Table of Content

Preface xxv

Acknowledgments xxix

About the Author xxxi

Chapter 1: Introduction: Joint Ventures Involving Exempt Organizations 1

Chapter 2: Taxation of Charitable Organizations 49

Chapter 3: Taxation of Partnerships and Joint Ventures 193

Chapter 4: Overview: Joint Ventures Involving Exempt Organizations 291

Chapter 5: Private Benefit, Private Inurement, and Excess Benefit Transactions 409

Chapter 6: Engaging in a Joint Venture: The Choices 489

Chapter 7: Exempt Organizations as Accommodating Parties in Tax Shelter Transactions 561

Chapter 8: The Unrelated Business Income Tax 577

Chapter 9: Debt-Financed Income 669

Chapter 10: Limitation on Excess Business Holdings 697

Chapter 11: Impact on Taxable Joint Ventures: Tax-Exempt Entity Leasing Rules 709

Chapter 12: Healthcare Entities in Joint Ventures 729

Chapter 13: Low-Income Housing, New Markets, Rehabilitation, and Other Tax Credit Programs 939

Chapter 14: Joint Ventures with Universities 1101

Chapter 15: Business Leagues Engaged in Joint Ventures 1171

Chapter 16: Conservation Organizations in Joint Ventures 1199

Chapter 17: International Joint Ventures 1235

Chapter 18: The Exempt Organization as Lender or Ground Lessor 1291

Chapter 19: Debt Restructuring and Asset Protection Issues 1335

Index 1399

About the author

MICHAEL I. SANDERS is the lead partner of Blank Rome’s Washington office’s tax group with a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit transactions. He is also an adjunct professor at The George Washington University Law School and Georgetown University Law Center. He was recently honored in 2010 by The George Washington University Law School for his 35 years of teaching.