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CANCELLED Advanced UBIT: Charities Holding Equity Interests in a Business or Joint Venture
Thu, October 12, 2017 10:00 A.M.
Parkway Central Library
This program has been cancelled and will be rescheduled for the spring of 2018. We apologize for any inconvenience.
Ms. Conley and Ms. Unterseher will introduce the unrelated business income tax (known as “UBIT”) and describe how UBIT typically applies to tax-exempt entities such as 501(c)(3) public charities and private foundations. They’ll demonstrate how UBIT concepts apply to activities conducted in a subsidiary entity, such as a traditional for-profit corporation, a public benefit corporation, a limited liability company, or a partnership, and will also introduce the concept of excess business holding restrictions applicable to private foundations and donor advised funds.
This program will examine legal issues raised in a few common scenarios where charities choose to form a new subsidiary, invest in an existing business enterprise, or otherwise obtain such an ownership interest in a legal transaction, such as:
- Fundraising, where a public charity might accept an illiquid asset such as real estate or an interest in a partnership or hedge fund, anticipating using funds from liquidation of that illiquid asset for grant making;
- Growing charitable activities, such as by collaborating with a for profit partner to enhance a particular charitable service;
- Managing traditional investment portfolios that include partnership investments;
- Leveraging opportunities for revenue enhancement, such as by commercializing an asset of the charity, which might be real estate or intellectual property; or
- Investing in a for-profit business or a charitable grantee, such as through mission-related investing or catalytic investing sometimes called a program related investment (known as a “PRI”).
Marla Conley is a founding partner of Conley Fleming LLP where she focuses her practice on serving nonprofit organizations and their donors.
Molly Unterseher is an associate at Conley Fleming LLP where she focuses her practice on advising a variety of tax-exempt organizations, including private foundations, public charities, and donor-advised funds.
Advance registration is required as space is limited; please contact the RFC at email@example.com.
Parkway Central Library
1901 Vine Street (between 19th and 20th Streets on the Parkway)
Philadelphia, PA 19103