Tax-Exempt Organizations

Nonprofit organizations operate in a regulatory environment that is both highly specialized and increasingly scrutinized.  We advise tax-exempt entities across all stages of their lifecycle, including newly formed nonprofits, long-standing public charities, private foundations, donor-advised funds, and hybrid structures with both charitable and commercial elements.  Our work focuses on ensuring that organizations are properly formed, compliant, and strategically positioned to carry out their missions without exposing themselves or their leadership to unnecessary regulatory, fiduciary, or operational risk.

We regularly assist clients in obtaining and maintaining federal tax-exempt status under §501(c), navigating state charitable registration requirements, and developing governance frameworks that withstands scrutiny from both the IRS and Attorney General’s offices.  This includes structuring and documenting board governance practices, conflict-of-interest policies, compensation arrangements, grantmaking procedures, and internal controls.  Because we have extensive experience handling fiduciary disputes and governance litigation in the commercial sector, we bring a heightened focus on risk allocation, oversight, and documentation.

When disputes or examinations arise, we represent nonprofits before the IRS, state Attorneys General, and other oversight bodies.  We also guide organizations through mergers, affiliations, restructurings, and dissolutions, ensuring compliance with state nonprofit corporation laws, charitable-asset restrictions, and donor-intent requirements.  Our work spans the full range of modern nonprofit activity, from creating donor-advised funds and charitable trusts to advising on cross-border operations, governance transitions, and high-value gift acceptance.

Our tax-exempt organization work includes:

  • Formation and Qualification under §501(c)

  • Charitable Registration & Compliance

  • Private Foundation Rules & Excise Taxes

  • Unrelated Business Income Tax (UBIT)

  • Joint Ventures with For-Profit Entities

  • Governance & Fiduciary Duties of Nonprofit Boards

  • Endowment & Investment Management

  • IRS Examinations and State Attorney General Oversight

  • Nonprofit Mergers, Affiliations & Dissolutions

  • Donor-Advised Funds & Charitable Trusts