Topic
Charitable Purpose
18 published works
Nonprofit Law Prof Blog
Last Thoughts on Supporting Warriors as a Charitable Purpose
Every country grants tax exemption for supporting its own troops. Humanitarian support, I mean. Care packages. That can be half-way justified by the assertion that supporting one's own troops relieves…
Nonprofit Law Prof Blog
Why Even Have an Unrelated Business Income Tax?
Nowadays we pretty much take for granted that an activity does not merit tax exemption just because the profits are fed to a charitable activity. That's why we have IRC…
Nonprofit Law Prof Blog
Elon Musk Sues OpenAI For its “Hot-Air Philanthropy”
We told you earlier this year that Elon Musk, once a big supporter of tax-exempt OpenAI, sued Sam Altman and all the other effective altruists involved with OpenAI. In that…
Nonprofit Law Blog
Charitable: Eliminating Prejudice and Discrimination
Charitable purposes under IRC Section 501(c)(3) include the promotion of social welfare by organizations that conduct activities to eliminate prejudice and discrimination. See Treas. Reg. 1.501(c)(3)-1(d)(2). The IRS Exempt Organizations…
Nonprofit Law Prof Blog
Organizing A Bloodless Coup d’état is Not a Charitable Purpose, Service Rules
An organization's admitted purpose to peacefully take over a foreign country's government and become the people's benevolent leader is not charitable. No kidding. Here are excerpts from PLR 202316011, released…
Nonprofit Law Blog
WCTEO 2020 Highlights: Charitable Purpose in the 21st Century
The following are some of the highlights from the session on Charitable Purpose in the 21st Century at the 2020 Western Conference on Tax Exempt Organizations (WCTEO): Historical context: Rev.…
Texas Trusts, Estates and Taxes
When a Charity Wants to Change It’s Mission
March of Dimes was created to deal with polio, and was left without a mission once a vaccine was developed. So with a nationwide infrastructure in place, it decided to…
Nonprofit Law Prof Blog
Ebenezer Scrooge on Tax Exempt Status for Pups.
I am feeling a little like Ebenezer Scrooge today so I thought I would raise an objection to tax exempt status for a group of very friendly people who, nevertheless,…
Nonprofit Law Prof Blog
Supreme Court Strikes Down Ban on “Action Organizations”
My life as a military brat, particularly in Germany, taught me that the world does not begin and end on the shores of North America. So if you clicked on…
Nonprofit Law Prof Blog
Should we eliminate the idea of the nonprofit sector?
In a Forbes article from earlier this week, the author calls into question the charitable purpose and tax-exempt status of prestigious schools like Harvard and Stanford. The author argues that…