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§ 3.5 UNRELATED BUSINESS RULES• A trade or business carried on by the organization primarily for the “convenienceof its members, students, patients, officers, or employees.” 481This exemption is available only to organizations that are charitable entities482 or are governmental colleges and universities. 483• A trade or business “which is the selling of merchandise, substantiallyall of which has been received by the organization as gifts or contributions.”484• Qualified public entertainment activities, 485 which are “any entertainment orrecreational activity of a kind traditionally conducted at fairs or expositionspromoting agricultural and educational purposes, including, butnot limited to, any activity one of the purposes of which is to attract thepublic to fairs or expositions or to promote the breeding of animals or thedevelopment of products or equipment.” 486 This exemption is availableonly to charitable, social welfare, labor, and agricultural organizations. 487• Qualified convention and trade show activities, 488 which are “any activity of akind traditionally conducted at conventions, annual meetings, or tradeshows, including, but not limited to, any activity one of the purposes ofwhich is to attract persons in an industry generally (without regard tomembership in the sponsoring organization) as well as members of thepublic to the show for the purpose of displaying industry products or tostimulate interest in, and demand for, industry products or services, or toeducate persons engaged in the industry in the development of newproducts and services or new rules and regulations affecting the industry.”489 This exemption is available only to charitable, social welfare, labor,and agricultural organizations, and business leagues. 490• In the case of a charitable hospital, the furnishing of certain cooperativeservices to one or more small hospitals under certain circumstances. 491• The conduct of certain bingo games. 492• In the case of charitable and veterans’ organizations, contributions towhich are deductible for federal income tax purposes, 493 activities relating481 IRC § 513(a)(2).482 That is, organizations that are described in IRC § 501(c)(3).483 That is, institutions that are described in IRC § 511(a)(2)(B).484 IRC § 513(a)(3).485 IRC § 513(d).486 IRC § 513(d)(2)(A).487 That is, organizations described in IRC §§ 501(c)(3), (4), or (5), respectively. Social welfare organizations arethe subject of Tax-Exempt Organizations ch. 12, and labor and agricultural organizations are the subject of id.ch. 15.488 IRC § 513(d).489 IRC § 513(d)(3)(A).490 That is, organizations described in IRC §§ 501(c)(3), (4), (5), or (6), respectively. Business leagues are the subjectof Tax-Exempt Organizations ch. 13.491 IRC § 513(e).492 IRC § 513(f).493 See § 3.3. 119

§ 3.5 UNRELATED BUSINESS RULES• A trade or business carried on by the organization primarily for the “convenienceof its members, students, patients, officers, or employees.” 481This exemption is available only to organizations that are charitable entities482 or are governmental colleges and universities. 483• A trade or business “which is the selling of merchandise, substantiallyall of which has been received by the organization as gifts or contributions.”484• Qualified public entertainment activities, 485 which are “any entertainment orrecreational activity of a kind traditionally conducted at fairs or expositionspromoting agricultural and educational purposes, including, butnot limited to, any activity one of the purposes of which is to attract thepublic to fairs or expositions or to promote the breeding of animals or thedevelopment of products or equipment.” 486 This exemption is availableonly to charitable, social welfare, labor, and agricultural organizations. 487• Qualified convention and trade show activities, 488 which are “any activity of akind traditionally conducted at conventions, annual meetings, or tradeshows, including, but not limited to, any activity one of the purposes ofwhich is to attract persons in an industry generally (without regard tomembership in the sponsoring organization) as well as members of thepublic to the show for the purpose of displaying industry products or tostimulate interest in, and demand for, industry products or services, or toeducate persons engaged in the industry in the development of newproducts and services or new rules and regulations affecting the industry.”489 This exemption is available only to charitable, social welfare, labor,and agricultural organizations, and business leagues. 490• In the case of a charitable hospital, the furnishing of certain cooperativeservices to one or more small hospitals under certain circumstances. 491• The conduct of certain bingo games. 492• In the case of charitable and veterans’ organizations, contributions towhich are deductible for federal income tax purposes, 493 activities relating481 IRC § 513(a)(2).482 That is, organizations that are described in IRC § 501(c)(3).483 That is, institutions that are described in IRC § 511(a)(2)(B).484 IRC § 513(a)(3).485 IRC § 513(d).486 IRC § 513(d)(2)(A).487 That is, organizations described in IRC §§ 501(c)(3), (4), or (5), respectively. Social welfare organizations arethe subject of Tax-Exempt Organizations ch. 12, and labor and agricultural organizations are the subject of id.ch. 15.488 IRC § 513(d).489 IRC § 513(d)(3)(A).490 That is, organizations described in IRC §§ 501(c)(3), (4), (5), or (6), respectively. Business leagues are the subjectof Tax-Exempt Organizations ch. 13.491 IRC § 513(e).492 IRC § 513(f).493 See § 3.3. 119

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