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95 COMMENTARY Joint Ventures Between Nonprofits and For-Profits: Will Revenue Ruling 2004–51 Provide Any Comfort? Andrew H. Foster Introduction Joint venture arrangements between tax-exempt organizations and forproofi entities are a common and increasingly important feature of affordabbl housing and community development transactions.1 Because of the high level of scrutiny by the Internal Revenue Service (IRS), such arrangemeent can also be risky, particularly for the tax-exempt party in the...

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