Tax-exempt bonds and sponsored research

"Sponsored research," wherein a business corporation or the government pays a portion of the cost of research activities carried out by a university or hospital, is increasingly important both for state institutions and for Section 510(c)(3) organizations. Sponsored research arrangements that are not properly structured can jeopardize the status of tax-exempt bonds issued to finance the facility at which the sponsored research occurs. While these rules have been difficult to apply in practice, properly structured agreements can provide funding for research without undue risk. This Article discusses the multiple pieces of guidance put forth by the Internal Revenue Service to clarify the many issues and tiers of analysis necessary to ensure a properly-structured sponsored research agreement.