Earlier this month, the IRS denied the exemption application of an organization whose articles stated that it would provide colleges and universities with the ability to engage in science and engineering studies and research in the submarine environment, including the ability to acquire by purchase, lease, gift, loan or by other means, vessels, vehicles and ancillary […]
commerciality doctrine
Unrelated Business Income and the Commerciality Doctrine
As is clearly determined (and as we’ve discussed several times on the Nonprofit Law Blog), in order to establish and maintain tax exemption under Section 501(c)(3), an organization must be primarily operated for an exempt purpose. What is less clearly determined, however, is when a 501(c)(3)’s tax exempt status may be at jeopardy by operation […]