The Tax Law of Colleges and Universities / Edition 3

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Institutions of higher education are under increasing scrutiny from the Internal Revenue Service for the wide spectrum of unrelated business income they can generate, from real estate income to football ticket sales. From one of the leading attorneys in this special field, here is a comprehensive guide to the tax rules these institutions face. Also includes thorough coverage of employment taxes, fringe benefits, lobbying and other political activities, plus strategies for handling an IRS audit.
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Product Details

  • ISBN-13: 9780470146095
  • Publisher: Wiley, John & Sons, Incorporated
  • Publication date: 10/26/2007
  • Series: Wiley Nonprofit Law, Finance and Management Series, #223
  • Edition description: REV
  • Edition number: 3
  • Pages: 552
  • Product dimensions: 7.32 (w) x 10.04 (h) x 1.64 (d)

Meet the Author

Bertrand M. Harding, Jr., operated his own law firm in Washington, D.C., where he specializes in nonprofit tax law with emphasis on tax issues and problems facing colleges, universities, and international educational organizations. A substantial component of his practice also involves representation of colleges, universities, and other nonprofit organizations in controversies with the Internal revenue Service, including in audits, in all levels of administrative appeal, and in court. He speaks frequently to groups involved in college and university tax issues and sponsors a website, the College & University Tax Page (, which contains analyses of current issues and other topical information relating to college and university tax matters.

Mr. Harding's interest and involvement in nonprofit tax law began in the early 1970's when he worked for the IRS Exempt Organizations Division while attending the George Washington National Law center in the evenings. After graduation from law school in 1975, Mr. Harding served for two years as an attorney-advisor to the Honorable Judge Bruce M. Forrester, United States tax Court. In 1977, he joined the Washington office of the international law firm of Baker & McKenzie, where he was elected a tax partner in 1984. While at baker & McKenzie, Mr. Harding represented a number of clients in tax controversy matters and, in addition, developed a nonprofit tax practice drawing on the knowledge and experience that he had gained while working at the Internal revenue Service. In 1996, he left baker & McKenzie to establish his own law firm specializing in nonprofit tax matters an representation of clients in tax controversies with the Internal revenuer Service.

Mr. Harding received his B.A. from Duke University in 1968, and he is a member of the Exempt Organizations Committee of the American Bar Association.

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Table of Contents

Ch. 1 Historical Overview of College and University Taxation 1
Ch. 2 Unrelated Business Income 7
Ch. 3 Common Activities Conducted by Colleges and Universities that Raise Unrelated Business Income Tax Concerns 47
Ch. 4 Employment Taxes 87
Ch. 5 Fringe Benefits 121
Ch. 6 Charitable Contribution Deductions 151
Ch. 7 Scholarships and Fellowships 171
Ch. 8 Special Issues and Problems 189
Ch. 9 IRS Audits of Colleges and Universities 251
App. A IRS Notice 87-31 283
App. B Revenue Ruling 87-41 289
App. C IRS Audit Guidelines for Colleges and Universities 299
App. D IRS Audit Guidelines for 403(b) Plans 315
App. E IRS Training Manual on Worker Classification 335
Index and Tables 373
Index 373
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