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IRS Attacks Impact Investing With Flawed Logic: A Critical Review of the IRS Argument

On October 9th, the Internal Revenue Service released Private Letter Ruling 202041009 (the “Ruling”), which, in what many in the nonprofit community would have expected to be a relatively straight-forward exemption approval...more

IRS Ruling Takes Aim at Impact Investing

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more

Using Endowed Funds in a Crisis: Key Considerations

It goes without saying that we are living in uncertain times and are experiencing events that are reshaping our lives in ways that many of us believed only to exist in science fiction books and movies. Nevertheless, while we...more

IRS Releases Interim Guidance for Exempt Organizations on New Unrelated Business Income Tax Rules

The IRS and Treasury Department recently released new guidance for calculating the tax on unrelated business income (“UBI”) activities of tax-exempt organizations with more than one UBI activity. With the passage of the 2017...more

Tax Bill Causes Alarm for Some Charities and Tax-Exempt Organizations

The Tax Cuts and Jobs Act, which has been renamed the Amendment of 1986 Code, was signed into law by President Trump on December 22, 2017. Many are calling it the most sweeping overhaul to the United States tax system in...more

IRS Issues Long-Awaited Final Regulations for Charitable Hospitals

In This Issue: - What You Should Do - Background - Final Regulations - Hospital Facilities and Organizations - Failures to Satisfy the Requirements of Section 501(r) - Community...more

Hospital's Lab Testing for Non-Patients Held to be Related Activity

On July 11, 2014, the IRS released a Technical Advice Memorandum ("TAM") finding that a tax-exempt hospital's income from the performance of laboratory services for non-patients was not subject to the unrelated business...more

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