CHAPTER SIXTEENFor‐Profit Subsidiaries
§ 16.3 ATTRIBUTION OF SUBSIDIARY'S ACTIVITIES TO EXEMPT PARENT
p. 387, second complete paragraph. Insert as last sentence:
To extrapolate from the higher education context, the IRS ruled that a tax‐exempt university did not have its for‐profit subsidiary's activities attributed to it, with the IRS stressing that the subsidiary was a “separate legal entity” with its own “activities and management”; the subsidiary was said to have a “real and substantial business purpose.”81.1
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