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Public charities--such as hospitals and educational institutions, scientific research foundations, low-income housing organizations and trade associations--benefit from sage advice on obtaining and maintaining a federal tax exemption.
Our exempt organizations lawyers include a former Executive in the Chief Counsel's Office, IRS, dealing with the largest exempt organizations controversies; a former U.S. Tax Court Attorney-Advisor; a former Attorney-Advisor to the Assistant Secretary of Tax Policy in the Office of Tax Legislative Counsel, Department of Treasury; a former U.S. Department of Justice Trial Attorney; the author of the highly regarded book Joint Ventures Involving Tax-Exempt Organizations; and a tax professor.
Together, we have:
- Obtained IRS "determination letters" that exempt organizations from federal taxation
- Assisted clients in minimizing unrelated business taxable income
- Established and maintained private foundations for entities and individuals
- Structured joint ventures and other strategic alliances between exempt organizations and for-profit enterprises, including health care entities
- Established taxable subsidiaries and other affiliates of exempt organizations, including health care organizations
- Structured licensing arrangements between exempt organizations and for-profit enterprises
- Advised exempt organizations on tax aspects of Internet activities
- Represented exempt organizations before the IRS and state tax authorities in examinations of tax returns and litigation of tax controversies
- Advised exempt organizations and executives on executive compensation in light of intermediate sanctions
- Established politically active exempt organizations as social welfare organizations, labor organizations or political organizations, depending on which is most advantageous
- Advised section 527 organizations on new disclosure rules
- Counseled exempt organizations on International Philanthropy
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