Articles

Despite a lack of definition in Section 501(c)(3) of the Tax Code or the Regulations, the IRS and the courts have used the term “in its generally accepted legal sense”

An organization will not qualify for charitable exemption if it provides private benefit which is not quantitatively and qualitatively incidental to the public benefit of its activities.

Neither the Tax Code nor the Regulations provides a definition; The IRS uses a 14-point set of guidelines, plus the other limitations of Section 501(c)(3)

Nonprofits will lose tax exempt status if they do not have control over whole hospital joint ventures with for-profit organizations

Intermediate Sanctions statute imposes tax on "disqualified persons" who receive more from a transaction with a nonprofit than they give in return.

Service will make judgment call based on “all relevant facts and circumstances” By Eric Vieland Montgomery McCracken

Benefits not reported as compensation when paid will be treated as excess even though total compensation is reasonable