Tax-exempt organizations

TOPICS / TAX

August 1, 2026

NIL organization denied tax-exempt status

The IRS denied tax-exempt status to an organization formed to compensate student-athletes for the use of their name, image, and likeness (NIL), concluding that the organization served private rather than public interests and operated for a substantial nonexempt purpose.

February 1, 2026

Basketball officials’ association denied Sec. 501(c)(3) status

The association failed to meet both the organizational and operational tests under Sec. 501(c)(3) and failed to qualify as a “qualified amateur sports organization” under Sec. 501(j)(2).

June 1, 2025

Business networking organization denied tax-exempt status

The corporation primarily facilitates referrals among its members, a business activity, the IRS determined.

April 1, 2025

Pickleball club denied tax-exempt status

In a letter ruling, the IRS determined that a recreational community club was not a qualified amateur sports organization.

March 1, 2025

Fifth Circuit affirms denial of accountable care organization’s tax exemption

Finding that the organization was not operated exclusively for the promotion of social welfare, the Fifth Circuit affirmed the Tax Court’s judgment.

January 1, 2025

When does a tax-exempt organization qualify for the ERC under the controlled-group rules?

A reasonable, good-faith interpretation of the rules must be applied, the IRS Chief Counsel’s Office states.

November 1, 2024

NIL organization denied tax-exempt status

Compensating student-athletes for their name, image, and likeness does not serve an exempt purpose, the IRS again rules.

October 30, 2024

BOI reporting deadlines extended for certain victims of 5 hurricanes

The AICPA had requested that the Financial Crimes Enforcement Network extend reporting deadlines for beneficial ownership information for victims of hurricanes Beryl, Debby, Francine, Helene, and Milton.

August 1, 2024

What not-for-profits need to know about UBIT

CPAs can help not-for-profits understand what revenue is subject to the unrelated business income tax (UBIT) and navigate the rules surrounding the tax.

February 22, 2024

The clean-energy direct-pay election for not-for-profits and governmental entities

Under the Sec. 6417 direct-pay election, tax-exempt organizations, including not-for-profits and governmental agencies, can claim certain energy credits on their federal income tax returns, but to claim them for 2023, the direct-pay election must be made on a timely filed 2023 federal income tax return.

September 1, 2023

Most NIL collectives likely ineligible for tax-exempt status, IRS advises

A Chief Counsel legal memo concludes that organizations supporting compensation to college student-athletes for their name, image, and likeness (NIL) generally have a substantial nonexempt purpose.

June 14, 2023

IRS addresses whether college NIL collectives further an exempt purpose

A memo from the IRS Office of Chief Counsel advises that an organization that develops paid NIL opportunities for student-athletes will, in many cases, be operating for a substantial nonexempt purpose—serving the private interests of student-athletes—which is more than incidental to any exempt purpose furthered by the activity.

May 1, 2022

No step-up in basis for private foundation’s assets

A PMTA disagrees with a prior letter ruling.

March 25, 2022

Various exempt organization notices paused

Citing processing delays, the IRS suspends 10 late-filing notices to tax-exempt organizations.

March 1, 2022

IRS diagnoses a defect in Mayo Clinic

The Eighth Circuit’s decision
was a partial win for the Service,
which nonetheless does not
acquiesce to the court’s holding
regarding the formal-instruction
requirement for tax-exempt
educational institutions.

September 1, 2021

Former state senator held to be a disqualified person with respect to charity

Tax Court holds against a former Pennsylvania legislator despite his never having been the organization’s officer or employee.

May 24, 2021

Sorting out tax exempts’ UBTI painlessly

To help exempt organizations “silo,” or separately compute, their unrelated business or trade income, three experts who will be giving a presentation on the topic at the upcoming Not-for-Profit Industry Conference offer their thoughts.

May 1, 2021

Deduction denied for home donated as salvage

The Fourth Circuit affirms that, without recording a transfer of ownership, the owners’ interest in the property was not severed.

March 1, 2021

President of not-for-profit organization denied passthrough losses

The Tax Court held that the taxpayer had no ownership interest that would generate passthrough losses.

March 1, 2021

Managing the ‘excess compensation’ tax

Highly paid employees require some exempt organizations to pay an excise tax.

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