CHAPTER 4Charitable Organizations
- 4.1 Relief of the Poor
- 4.2 Promotion of Social Welfare
- 4.3 Lessening the Burdens of Government
- 4.4 Advancement of Religion
- 4.5 Advancement of Education and Science
- 4.6 Promotion of Health
- (a) Charity Care
- (b) Private Inurement
- (c) Hospital Joint Ventures
- (d) Physician Clinics
- (e) Integrated Health-Care Delivery Systems
- (f) Health Maintenance Organizations
- (g) Health/Fitness Centers
- (h) Professional Standards Review Organizations
- (i) Homes for the Elderly
- (j) §501(r) Requirements for Hospitals
- 4.7 Cooperative Hospital Service Organizations
The second type of activity qualified for exemption under Internal Revenue Code (IRC) §501(c)(3) is charitable, which is expansively defined “in its generally accepted legal sense,” meaning much more than relief of the poor.1 Charity is an evolving concept, fashioned over the years by societal need. The definition sometimes also depends on the policies of the administration currently in the White House: A shelter to house Vietnamese refugees qualified for exemption in 1978; but in 1987, the application for exemption for a similar shelter for Central American refugees was denied because the activity was “against government policy.”
Charity connotes broad public benefit that is accomplished either by giving direct financial support to individuals and organizations ...
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