Listed below is a series of articles published as the Exempt Organizations Continuing Professional Education (CPE) Technical Instruction Program for Fiscal Year 1986. The 1986 series of articles were published in January 1986. These materials were designed specifically for training purposes only. Under no circumstances should the contents of these articles be used or cited as authority for setting or sustaining a technical position. The freely available Adobe Acrobat Reader software is required to view, print and search these files. Representation of Taxpayers Before the Internal Revenue ServicePDF Highlights of the regulatory provisions which govern the representation of taxpayers before the IRS. Whether Share Crop Income is Excluded from Unrelated Business Income under IRC 512(b)(3)(A) as Rental IncomePDF A discussion of whether share crop income received by an exempt organization is excluded from unrelated business income under IRC 512(b)(3)(A) as rental income. IRC 501(c)(2) - Title-Holding CorporationsPDF Use of title-holding organizations as investment vehicles for pension plans and other exempt organizations, with a focus on the issue of multiple parents under IRC 501(c)(2). IRC 501(k) - Child Care OrganizationsPDF Review of the legislative history of IRC 501(k) and the IRS position on child care organizations, and description of the current status of efforts to provide further guidance in administering the provision. For-Profit Subsidiaries of Exempt OrganizationsPDF A discussion of whether the activities of a taxable subsidiary will jeopardize its parent exempt organization's tax-exempt status or result in unrelated business taxable income. Insurance Activities of Exempt OrganizationsPDF Recent developments in the area of group insurance for members (UBI); exemption issues under IRC 501(c)(6); use of IRC 501(c)(9) VEBAs to provide insurance benefits to members of an IRC 501(c)(6) organization. Update on FundraisingPDF Discussion on first amendment issues, exemption of fundraising organizations that distribute funds to other organizations, charitable gaming issues, and unrelated business income tax developments relating to fundraising. IRC 501(c)(3) - Substantially Below CostPDF Circumstances under which an organization whose activities are not inherently religious, charitable, or educational may qualify for exemption on the basis that they provide services to other section 501(c0(3) organizations that, while commercial, are provided at substantially below cost. Adverse Determination CasesPDF Degree and nature of development necessary for cases and proper content and organization of adverse determination letters. Developments in Health CarePDF Unrelated business income tax issues for nonprofit health care organizations, and conversions from nonprofit to for-profit operation. The Use of Limited Partnerships to Accomplish Charitable ObjectivesPDF An update on issues under IRC 501(c)(3). Update on ChurchesPDF Overview of developments during 1985 that affect churches. Update on VEBAsPDF Update on voluntary employees' beneficiary associations, including a brief outline of 1984 legislation adopting new rules for the deductibility of employer contributions to VEBAs and other employee welfare benefit funds. IRC 514 - Unrelated Debt-Financed IncomePDF An in-depth discussion of the provisions of IRC 514, relating to the taxation of unrelated debt-financed income. Scientific Research under IRC 501(c)(3)PDF A framework for resolving exemption and unrelated business tax issues relating to scientific research. Veterans' OrganizationsPDF Exemption of veterans' organizations under IRC 501(c)(4), 501(c)(7), and 501(c)(19); deductibility of contributions to veterans' organizations; and unrelated business income tax issues for veterans' organizations.
