| re: What's being built next to the Imperial Theater? | |
| Posted by: ryhog 10:22 pm EST 01/03/25 | |
| In reply to: re: What's being built next to the Imperial Theater? - NewtonUK 08:53 am EST 01/03/25 | |
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| "My understanding, which may be incorrect" More than "may" my friend, and your own internal contradictions prove that. LOL 1. Assuming by "collusion" you mean the private IRS letter ruling establishing the arrangement you disparage, that letter was in the late 1970s, not in the 1940s. 2. Calling it collusion, no matter when the letter was written, is both libelous and a conspiracy theory lacking any evidence whatsoever and so silly that it would make even Marjorie Taylor Greene blush. 3. The foundation was not founded after J.J.'s death, as you confusedly state. One of the few correct things you said that is correct is that it was founded in the 40's. J.J. and Lee were the founders. 4. The request for the PLR was after J.J.'s death. It was submitted by Lee Seidler, a well-known tax expert who is still on the Board today, and Peat Marwick. 5. The requirement from which Shubert was exempted did not require selling for profit assets; it prohibited a foundation from owning a controlling interest in a for profit business. Obviously, a foundation can own stock in a for profit enterprise. The particular ruling was that the Foundation was an integral part of the Organizations business because it donated money to non-profit theatres and other performing arts. The IRS was persuaded to make this ruling because the application was submitted at a low point in the prospects of theatre. Historians point out that it is somewhat ironic that by the time it was implemented, the Shuberts had A Chorus Line on Broadway. Of course, a lot of folks thought it was an unwise ruling but that does not suggest collusion. The ends don't justify the means but it is worth noting that the Foundation is, by quite a distance as I recall, the largest grantor in the country to the performing arts community. 6. The foundation does not lease the theatres to the organization; although the foundation does and has owned some pretty substantial real estate, the for-profit organization owns the theatres. 7. Finally, understand that it is the after-tax profits that the Foundation does not pay tax on (same for all foundations and also you and me). That's not what makes the ruling significant; it is the controlling interest rule from which they were exempted, and incidentally while it was a surprising ruling, it was consistent with the code and the regulations. It seems we all should have learned this by now: as a one-time Broadway producer reminds us daily, making a point with false facts does not impress those who go to the trouble of apprehending the truth. "The truth will set you free." John 8:32. |
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