The Tax Law of Charitable Giving. Bruce R. Hopkins

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Название The Tax Law of Charitable Giving
Автор произведения Bruce R. Hopkins
Жанр Личностный рост
Серия
Издательство Личностный рост
Год выпуска 0
isbn 9781119756026



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competitors. Thus, specific business activities of a tax-exempt organization will generally “be deemed ‘regularly carried on’ if they manifest a frequency and continuity, and are pursued in a manner generally similar to comparable commercial activities of nonexempt organizations.”530

      Certain business activities conducted by tax-exempt organizations are exempt from unrelated business taxation. These include:

       A trade or business “in which substantially all the work in carrying on such trade or business is performed for the organization without compensation.”546

       A trade or business carried on by the organization primarily for the “convenience of its members, students, patients, officers, or employees.”547 This exemption is available only to organizations that are charitable entities548 or are governmental colleges and universities.549

       A trade or business “which is the selling of merchandise, substantially all of which has been received by the organization as gifts or contributions.”550

       Qualified public entertainment activities,551 which are “any entertainment or recreational activity of a kind traditionally conducted at fairs or expositions promoting agricultural and educational purposes, including, but not limited to, any activity one of the purposes of which is to attract the public to fairs or expositions or to promote the breeding of animals or the development of products or equipment.”552 This exemption is available only to charitable, social welfare, labor, and agricultural organizations.553

       Qualified convention and trade show activities,554 which are “any activity of a kind traditionally conducted at conventions, annual meetings, or trade shows, including, but not limited to, any activity one of the purposes of which is to attract persons in an industry generally (without regard to membership in the sponsoring organization) as well as members of the public to the show for the purpose of displaying industry products or to stimulate interest in, and demand for, industry products or services, or to educate persons engaged in the industry in the development of new products and services or new rules and regulations affecting the industry.”555 This exemption is available only to charitable, social welfare, labor, and agricultural organizations and to business leagues.556

       In the case of a charitable hospital, the furnishing of certain cooperative services to one or more small hospitals under certain circumstances.557

       The conduct