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IRS Issues Exempt Organizations Technical Guide for Disqualifying and Non-Exempt Activities for 501(c)(3) Organizations

On July 14, 2023, the IRS issued Technical Guide 3-10 for Disqualifying and Non-Exempt Activities – Trade or Business Activities – IRC Section 501(c)(3). The TG 3-10 discusses the “fragmentation” of nonprofit and for-profit...more

Treat People With Kindness (But Don’t Forget Secular Tax Law)

For tax-exempt public charities, benevolent acts must be considered within the guardrails of section 501(c)(3) of the Internal Revenue Code. To enjoy tax-exemption as an organization described in Section 501(c)(3), the...more

Adverse Rulings from the IRS Exempt Organizations Division. How Can Your Organization Learn from Others’ Mistakes?

On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more

Can a Nonprofit Fundraise for Another Nonprofit? Legal and Tax Considerations.

I’ve served as outside general counsel for nonprofit organizations across the nation for over 15 years. This question is re-occurring. So, I thought I would blog a little about it. Not legal or tax advice; just legal and tax...more

Can a Church or Other Public Charity Endorse a Candidate? Tax Treatment of Political Campaign and Lobbying of Tax-Exempt...

Joint Committee on Taxation Report on Tax Treatment of Political Campaign and Lobbying Activities of Tax-Exempt Organizations - On April 29, 2022, the Joint Committee on Taxation published its 35-page report (the “Report”)...more

Tax Exemption and Unrelated Business Income Tax (UBIT): The Framework (Part 1 of 3)

This Insights blog is Part 1 of a 3-Part series that provides a focused overview of the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal...more

Texas Religious Organizations Property Tax Exemption

Through nearly 20 years of law practice–15 of which have been focused on the representation of tax-exempt organizations–this writer has been involved in numerous seemingly simple–and some cutting edge–applications for...more

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