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The Law of Tax-Exempt Organizations, 2026 Supplement, 13th Edition

Name: The Law of Tax-Exempt Organizations, 2026 Supplement, 13th Edition
ISBN: 9781394354337

by Shane T. Hamilton, Bruce R. Hopkins

May 2026

Intermediate

368 pages

9h 30m

English

Wiley

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Cover
Table of Contents
Title Page
Copyright
About the Author
Preface
Book Citations
CHAPTER ONE: Definition of and Rationales for Tax-Exempt Organizations
§ 1.2 DEFINITION OF TAX-EXEMPT ORGANIZATION§ 1.4 POLITICAL PHILOSOPHY RATIONALE
CHAPTER TWO: Overview of Nonprofit Sector and Tax-Exempt Organizations
§ 2.1 PROFILE OF NONPROFIT SECTOR§ 2.2 ORGANIZATION OF IRSNotes
CHAPTER THREE: Tax Exemption: Source and Recognition
§ 3.2 RECOGNITION OF TAX EXEMPTION§ 3.3 RECOGNITION OF PUBLIC CHARITY, PRIVATE FOUNDATION STATUS

CHAPTER FOUR: Organizational, Operational, and Related Tests and Doctrines
§ 4.3 ORGANIZATIONAL TEST§ 4.4 SUBSTANTIAL NONEXEMPT PURPOSES§ 4.5 OPERATIONAL TEST§ 4.6 FEEDER ORGANIZATIONS§ 4.7 COMMENSURATE TEST§ 4.9 COMMERCIALITY DOCTRINENotes
CHAPTER FIVE: Nonprofit Governance
§ 5.3 BOARD DUTIES AND RESPONSIBILITIESNote
CHAPTER SIX: Concept of Charitable
§ 6.2 PUBLIC POLICY DOCTRINE§ 6.3 COLLATERAL CONCEPTSNotes
CHAPTER SEVEN: Charitable Organizations
§ 7.2 RELIEF OF DISTRESSED§ 7.3 CREDIT COUNSELING§ 7.6 PROMOTION OF HEALTH§ 7.13 CONSORTIA§ 7.14 FUNDRAISING ORGANIZATIONS§ 7.15 GOVERNMENT ENTITIES AS CHARITABLE COUNTERPARTS§ 7.16 OTHER CATEGORIES OF CHARITY§ 7.18 CHARITABLE GRANTS TO INDIVIDUALSNotes
CHAPTER EIGHT: Educational Organizations
§ 8.3 EDUCATIONAL INSTITUTIONS§ 8.4 INSTRUCTION OF INDIVIDUALS§ 8.5 INSTRUCTION OF PUBLICNotes
CHAPTER NINE: Scientific Organizations
§ 9.5 TECHNOLOGY TRANSFER
CHAPTER TEN: Religious Organizations
§ 10.1 CONSTITUTIONAL LAW FRAMEWORK§ 10.3 CHURCHES AND SIMILAR INSTITUTIONS§ 10.8 APOSTOLIC ORGANIZATIONSNotes
CHAPTER ELEVEN: Other Types of Charitable Organizations
§ 11.2 AMATEUR SPORTS ORGANIZATIONS§ 11.6 CHARITABLE RISK POOLSNotes
CHAPTER TWELVE: Public Charities and Private Foundations
§ 12.1 FEDERAL TAX LAW DEFINITION OF PRIVATE FOUNDATION§ 12.3 CATEGORIES OF PUBLIC CHARITIES§ 12.5 DONOR-ADVISED FUNDS§ 12.6 ENDOWMENT FUNDSNotes
CHAPTER THIRTEEN: Social Welfare Organizations
§ 13.1 CONCEPT OF SOCIAL WELFARE§ 13.2 REQUIREMENT OF COMMUNITY§ 13.3 CONDUCT OF BUSINESS§ 13.4 ADVOCACY ORGANIZATIONSNotes
CHAPTER FOURTEEN: Business Leagues and Similar Organizations
§ 14.1 CONCEPT OF BUSINESS LEAGUE§ 14.2 DISQUALIFYING ACTIVITIES§ 14.3 CHAMBERS OF COMMERCENotes
CHAPTER FIFTEEN: Social Clubs
§ 15.1 SOCIAL CLUBS IN GENERAL§ 15.2 PUBLIC USE AND INVESTMENT INCOME LIMITATIONS§ 15.3 EXCEPTION TO LIMITATIONS FOR UNUSUAL AMOUNTSNotes
CHAPTER SIXTEEN: Labor, Agricultural, and Horticultural Organizations
§ 16.1 LABOR ORGANIZATIONSNote
CHAPTER SEVENTEEN: Political Organizations
§ 17.4 PUBLIC POLICY ADVOCACY ACTIVITIESNotes
CHAPTER EIGHTEEN: Employee Benefit Funds
§ 18.3 VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATIONS
CHAPTER NINETEEN: Other Categories of Tax-Exempt Organizations
§ 19.5 BENEVOLENT OR MUTUAL ORGANIZATIONS§ 19.6 CEMETERY COMPANIES§ 19.18 QUALIFIED HEALTH INSURANCE ISSUER§ 19.19 QUALIFIED TUITION PROGRAMS§ 19.20 ABLE PROGRAMS§ 19.22 GOVERNMENTAL AND QUASI-GOVERNMENTAL ENTITIES§ 19.23 NATIVE AMERICAN TRIBESNotes
CHAPTER TWENTY: Private Inurement and Private Benefit Doctrines
§ 20.1 CONCEPT OF PRIVATE INUREMENT§ 20.4 COMPENSATION ISSUES§ 20.5 EXCESS EXECUTIVE COMPENSATION TAX§ 20.6 OTHER FORMS OF PRIVATE INUREMENT§ 20.8 INCIDENTAL PRIVATE INUREMENT§ 20.12 PRIVATE INUREMENT AND OTHER CATEGORIES OF EXEMPT ORGANIZATIONS§ 20.13 PRIVATE BENEFIT DOCTRINENotes
CHAPTER TWENTY-ONE: Intermediate Sanctions
§ 21.2 TAX-EXEMPT ORGANIZATIONS INVOLVED§ 21.3 DISQUALIFIED PERSONS§ 21.4 EXCESS BENEFIT TRANSACTIONS§ 21.10 EXCISE TAX REGIME§ 21.14 RETURN FOR PAYMENT OF EXCISE TAXESNotes
CHAPTER TWENTY-TWO: Legislative Activities by Tax-Exempt Organizations
§ 22.3 LOBBYING BY CHARITABLE ORGANIZATIONS§ 22.4 LOBBYING EXPENDITURES AND TAX SANCTIONS§ 22.5 LEGISLATIVE ACTIVITIES OF SOCIAL WELFARE ORGANIZATIONS§ 22.6 LEGISLATIVE ACTIVITIES OF BUSINESS LEAGUES§ 22.7 LEGISLATIVE ACTIVITIES OF OTHER EXEMPT ORGANIZATIONSNotes
CHAPTER TWENTY-THREE: Political Campaign Activities by Tax-Exempt Organizations
§ 23.1 INTRODUCTION§ 23.2 PROHIBITION ON CHARITABLE ORGANIZATIONS§ 23.3 POLITICAL CAMPAIGN EXPENDITURES AND TAX SANCTIONS§ 23.6 POLITICAL ACTIVITIES OF SOCIAL WELFARE ORGANIZATIONS§ 23.10 ADVOCACY COMMUNICATIONSNotes
CHAPTER TWENTY-FOUR: Unrelated Business: Basic Rules
§ 24.1 INTRODUCTION TO UNRELATED BUSINESS RULES§ 24.5 CONTEMPORARY APPLICATIONS OF UNRELATED BUSINESS RULES§ 24.9 COMMERCIAL-TYPE INSURANCENotes
CHAPTER TWENTY-FIVE: Unrelated Business: Modifications, Exceptions, Special Rules, and Taxation
§ 25.2 EXCEPTIONS§ 25.5 “BUCKETING” RULENotes
CHAPTER TWENTY-SIX: Exemption Recognition and Notice Processes
§ 26.1 RECOGNITION APPLICATION PROCEDURE§ 26.2 REQUIREMENTS FOR CHARITABLE ORGANIZATIONS§ 26.3 NONPRIVATE FOUNDATION STATUS§ 26.4 REQUIREMENTS FOR SOCIAL WELFARE ORGANIZATIONS§ 26.5 REQUIREMENTS FOR CERTAIN CREDIT COUNSELING ORGANIZATIONS§ 26.6 REQUIREMENTS FOR CERTAIN EMPLOYEE BENEFIT ORGANIZATIONS§ 26.8 REQUIREMENTS FOR CERTAIN HEALTH INSURANCE ISSUERS§ 26.10 RULES FOR OTHER CATEGORIES OF ORGANIZATIONS§ 26.11 GROUP EXEMPTION RULES§ 26.12 TERRORISM-RELATED SUSPENSION OF TAX EXEMPTION§ 26.13 NOTICE REQUIREMENTS FOR SOCIAL WELFARE ORGANIZATIONS§ 26.14 NOTICE REQUIREMENTS FOR POLITICAL ORGANIZATIONS§ 26.15 INTEGRAL PART DOCTRINE§ 26.16 FORFEITURE OF TAX EXEMPTIONNotes
CHAPTER TWENTY-SEVEN: Administrative and Litigation Procedures
§ 27.1 ADMINISTRATIVE PROCEDURES WHERE RECOGNITION DENIED§ 27.2 REVOCATION OR MODIFICATION OF TAX-EXEMPT STATUS: ADMINISTRATIVE PROCEDURES§ 27.3 RETROACTIVE REVOCATION OF TAX-EXEMPT STATUS§ 27.5 DENIAL OR REVOCATION OF TAX-EXEMPT STATUS: LITIGATION PROCEDURES§ 27.6 IRS EXAMINATION PROCEDURES AND PRACTICES§ 27.8 FAST-TRACK CASE SETTLEMENT PROGRAM§ 27.9 IRS DISCLOSURE TO STATE OFFICIALSNotes
CHAPTER TWENTY-EIGHT: Operational Requirements
§ 28.1 CHANGES IN OPERATIONS OR FORM§ 28.2 ANNUAL REPORTING RULES§ 28.4 AUTOMATIC REVOCATION FOR FAILURE TO FILE§ 28.5 CHARITABLE ORGANIZATION LISTING RELIANCE RULES§ 28.8 UNRELATED BUSINESS INCOME TAX RETURNS§ 28.9 DOCUMENT DISCLOSURE OBLIGATIONS OF IRS§ 28.10 DOCUMENT DISCLOSURE OBLIGATIONS OF EXEMPT ORGANIZATIONS§ 28.11 INFORMATION OR SERVICES DISCLOSURE§ 28.12 FUNDRAISING DISCLOSURE§ 28.13 INSURANCE ACTIVITIES§ 28.14 FEEDER ORGANIZATIONS§ 28.16 TAX-EXEMPT ORGANIZATIONS AND TAX SHELTERSNotes
CHAPTER TWENTY-NINE: Tax-Exempt Organizations and Exempt Subsidiaries
§ 29.1 SUBSIDIARIES BASICSNote
CHAPTER THIRTY: Tax-Exempt Organizations and for-Profit Subsidiaries
§ 30.6 REVENUE FROM FOR-PROFIT SUBSIDIARY§ 30.7 LIQUIDATIONS
CHAPTER THIRTY-ONE: Tax-Exempt Organizations and Joint Ventures
§ 31.1 PARTNERSHIPS AND JOINT VENTURE BASICS§ 31.4 ANCILLARY JOINT VENTURES
CHAPTER THIRTY-TWO: Tax-Exempt Organizations: Other Operations and Restructuring
§ 32.7 CONVERSION FROM NONEXEMPT TO EXEMPT STATUSNotes
About the Online Resources
APPENDIX A: Sources of Tax-Exempt Organizations Law
FEDERAL LAWJUDICIARYSTATE LAWPUBLICATIONSNotes
APPENDIX B: Internal Revenue Code Sections
APPENDIX C: Categories of Tax-Exempt Organizations
Table of Cases
Table of IRS Revenue Rulings
Table of IRS Revenue Procedures
Table of IRS Determinations Cited in Text
IRS PRIVATE LETTER RULINGSTECHNICAL ADVICE MEMORANDAGENERAL COUNSEL MEMORANDANote
Table of Other IRS Determinations
Cumulative Index
End User License Agreement

Content preview from The Law of Tax-Exempt Organizations, 2026 Supplement, 13th Edition

CHAPTER SIXConcept of Charitable

§ 6.2 PUBLIC POLICY DOCTRINE

(a) General Principles

p. 114, note 44. Insert following existing text:

This position was first adopted by the IRS more than a decade earlier (Rev. Rul. 71-447, 1971-2 C.B. 230).

p. 115, second complete paragraph, second sentence. Delete, including footnote, and insert:

As applied by the IRS, the public policy doctrine requires that an organization's activities are not “contrary to a clearly defined and established public policy.”⁵⁴

p. 115, note 55. Insert following existing text:

In this instance, the IRS viewed the violation of state fundraising laws, which are not criminal activities that would warrant the application of the illegality doctrine (see § 6.3(i)), as being “in conflict with express statutory restrictions” (Rev. Rul. 80-278, 1980-2 C.B. 175) and therefore a violation of the public policy doctrine. Thus, although Rev. Rul. 80-278, supra, indicates that activities that conflict with express statutory restrictions provide a distinct basis for revoking or denying recognition of exemption (id.), in application the IRS appears to view the public policy doctrine as subsuming this aspect of Rev. Rul. 80-278.

p. 115, note 56. Insert following existing text:

Neither the IRS nor the court specifically discussed the illegality ...

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The Law of Tax-Exempt Organizations, 2026 Supplement, 13th Edition

by Shane T. Hamilton, Bruce R. Hopkins

CHAPTER SIXConcept of Charitable