Tax for Non-profit Organizations

Our work in this field includes familiarity with the requirements for exemption under Section 501(c)(6) and Section 501(c)(3) of the Internal Revenue Code, including the corresponding restrictions on the operations of such exempt organizations. We have obtained many favorable exemption determination letters and rulings from the Internal Revenue Service, at both the local and national office levels. We have extensive experience in addressing private inurement issues, unrelated business income tax issues (including opportunities and problems relating to special rules, such as those for royalty income or debt-financed property) and the use of association-sponsored charitable and educational foundations. Further, cognizant of the need to generate income from sources other than dues, we have assisted a number of our clients in establishing separate for-profit subsidiaries to engage in activities of an unrelated business nature that, if substantial in scope, could jeopardize the tax-exempt status of the association. In recent years we have monitored closely the proposed legislative changes regarding taxation of unrelated business income and have alerted clients to proposals that pose a significant threat.

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