By NEO Law Group
Fiscal sponsorship is a term commonly understood to reference one type of relationship – where the fiscally sponsored project is operated within the fiscal sponsor with all project assets, liabilities, revenues, expenses, employees, and volunteers being the fiscal sponsor’s. But this model, commonly referred to as Model A, is...
The following are just some of the many highlights from the 2026 Western Conference on Tax Exempt Organizations (WCTEO). As with all of our posts capturing highlights of events, my interpretations, opinions, and selection of additional resources may be sprinkled with the information provided by the presenters. Tribute to Doug Mancino...
The 29th Annual Western Conference on Tax-Exempt Organizations (WCTEO), my #1 go-to conference every year for the past 20 years, will be held in Los Angeles on Thursday, March 12, and Friday, March 13. You can register here. Early Bird pricing ends today (January 31, 2026). The UCLA School of Law Lowell...
As part of last month’s American Bar Association Exempt Organizations Committee meeting, Karl Mill (Mill Law Center), Tom Schroeder (Davis Wright Tremaine), and I discussed the use of (1) illegality and (2) violations of fundamental public policy as independent bases for the revocation of tax-exempt status in these ‘not...
Here are some of the highlights from the American Bar Association Exempt Organizations Committee meeting held on January 16 as part of the ABA Midyear Tax Meeting. As with all of our posts capturing highlights of events, my interpretations, opinions, and additions of supplemental resources may be sprinkled in with the...
With heightened political rhetoric and public statements from the current federal administration suggesting that the government may target 501(c)(3) organizations that oppose its policies, it is understandable that many nonprofits are worried about losing their 501(c)(3) tax-exempt status. While the concern may be justified, the reality is that (so...
The joint Treasury and IRS Initial 2025-2026 Priority Guidance Plan was released on September 30, 2025. The Plan contains 105 guidance projects that are priorities for allocating Treasury Department and IRS resources during the 12-month period from July 1, 2025, through June 30, 2026. The following are the projects that may...
Last month, we published a post on the recently revised IRS EO Technical Guide: Disqualifying and Non-Exempt Activities, Inurement and Private Benefit. This month, we share some excerpts from the Exempt Organizations Technical Guide: Disqualifying and Non-Exempt Activities – Trade or Business Activities – IRC Section 501(c)(3). This Technical...
The IRS recently revised its Exempt Organizations Technical Guide: Disqualifying and Non-Exempt Activities, Inurement and Private Benefit – IRC Section 501(c)(3). Organizations exempt under Section 501(c)(3) of the Internal Revenue Code (Code) must avoid engaging in impermissible conduct. Such conduct includes providing private benefit and inurement. An otherwise qualifying...
In a stipulation included in a Joint Motion for Entry of Consent Judgment, the IRS stated that when a church communicates with its congregation in a customary manner concerning “electoral politics viewed through the lens of religious faith”, it’s not electioneering, which would be prohibited under Section 501(c)(3) of...