An American Perspective on Not-for-Profit Tax Concessions

An American Perspective on Not-for-Profit Tax

Concessions by Jon Forman

Alfred P. Murrah Professor of LawUniversity of Oklahoma

Norman, Oklahoma

Treasury SeminarCanberra

25 July 2011

http://www.oklahoma-map.org/road-map.htm

http://www.state-maps.org/

Outline

Overview of U.S. nonprofit law, with an emphasis on the role of the Internal Revenue Service in regulating nonprofits

React to your Treasury’s recent reform proposal

Review some recent tax reform proposals in the U.S.

2

Size of the Nonprofit Sector

1.5 million nonprofits, foundations, and religious congregations

http://www.independentsector.org/our_sector

Returns of Tax-Exempt Organizations, Fiscal Year 2010 Total 776,300

Internal Revenue Service Data Book, 2010, Table 13, http://www.irs.gov/pub/irs-soi/10databk.pdf

3

http://www.independentsector.org/our_sector

http://www.irs.gov/pub/irs-soi/10databk.pdf

More Nonprofit Statistics

501(c)(3)s filed 313,121 information returns for Tax Year 2007

Held nearly $2.7 trillion in assets Reported $1.4 trillion in revenue,

more than two-thirds of which came from program services (Figure A).

4http://www.irs.gov/pub/irs-soi/07eocharteobull.pdfhttp://www.irs.gov/pub/irs-soi/07eocharteobull.pdf

http://www.irs.gov/pub/irs-soi/07eocharteobull.pdfhttp://www.irs.gov/pub/irs-soi/07eocharteobull.pdf


5http://www.irs.gov/pub/irs-soi/07eocharteobull.pdfhttp://www.irs.gov/pub/irs-soi/07eocharteobull.pdf



6

Top 10 Charities, $billions

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Life Cycle of a Public Charity/Private Foundation

Organizations that meet the requirements of Internal Revenue Code section 501(c)(3) are exempt from federal income tax as charitable organizations.

In addition, contributions made to charitable organizations by individuals and corporations are deductible under Code section 170.

http://www.irs.gov/charities/charitable/article/0,,id=136459,00.html 8

Charities Every exempt charitable organization is classified

as either a public charity or a private foundation. Generally, organizations that are classified as

public charities are those that (i) are churches, hospitals, qualified medical research

organizations affiliated with hospitals, schools, colleges and universities,

(ii) have an active program of fundraising and receive contributions from many sources, including the general public, governmental agencies, corporations, private foundations or other public charities,

(iii) receive income from the conduct of activities in furtherance of the organization’s exempt purposes, or

(iv) actively function in a supporting relationship to one or more existing public charities.

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Private Foundations

Private foundations, in contrast, typically have a single major source of funding (usually gifts from one family or corporation rather than funding from many sources) and most have as their primary activity the making of grants to other charitable organizations and to individuals, rather than the direct operation of charitable programs.

10

Life Cycle of a Public Charity During its existence, a public charity has

numerous interactions with the IRS – from filing an application for recognition of tax-exempt status, to filing the required annual information returns, to making changes in its mission and purpose. The IRS provides information, explanations, guides, forms and publications on all of these subjects – they are available through this IRS Web site. The illustration below provides an easy-to-use way of linking to the documents most charities will need as they proceed though the phases of their “life cycle.”

Graphical depiction, http://www.irs.gov/pub/irs-tege/pc_lifecyclechart_062910.pdf

http://www.irs.gov/charities/charitable/article/0,,id=122670,00.html 11

Benefits of 501(c)(3) Status Tax exemption under Internal Revenue

Code (the Code) section 501(c)(3) provides a number of benefits: Exemption from Federal income tax; Tax-deductible contributions; Possible exemption from state income,

sales, and employment taxes; Reduced postal rates; Exemption from Federal unemployment tax;

and Tax-exempt financing.

http://www.stayexempt.irs.gov/Resource-Library/pdfs/Mod1_Summary.pdf 12

Tax-Exempt Organizations and 501(c)(3)s

A tax-exempt organization is a trust, unincorporated association, or nonprofit corporation described in the Internal Revenue Code as exempt from Federal income tax.

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501(c)(3) Charities A 501(c)(3) is a type of exempt organization. It

must be organized and operated for one or more exempt purposes described in Code section 501(c)(3): Charitable, Educational, Religious, Scientific, Literary, Testing for public safety, Fostering national or international amateur sports

competition, and/or Preventing cruelty to children or animals.

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Public Charity Status

When an entity qualifies as a 501(c)(3), the IRS presumes it is a private foundation (except for statutory public charities, such as churches and schools) unless the organization can show it is a public charity.

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Public Charity Status To qualify as a public charity, the 501(c)(3) must

demonstrate it is a type of organization classified as a public charity by statute such as a church, hospital or school, or that supports another public charity.

In addition, an organization may be classified as a public charity if it is publicly supported and receives substantial support in the form of gifts, grants and contributions from the general public or a governmental unit and or income from activities related to their exempt activities like admissions.

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Public Charity Status If your 501(c)(3) is so new that it cannot show it

is publicly supported, the IRS will treat you as a public charity for your first five years from the organization’s formation if it demonstrates that it can reasonably be expected to be publicly supported.

Beginning with the organization’s sixth year, the IRS will monitor your public charity status based on your public support as reported on Schedule A, Public Charity Status and Public Support of your Form 990.

If the organization cannot show broad financial support, the IRS will reclassify it as a private foundation.

17

Jeopardizing 501(c)(3) Status

There are four types of activities that can jeopardize a charity’s 501(c)(3)’s tax-exempt status: Private benefit/inurement, Lobbying, Political activity, and Excessive unrelated business income

(UBI).

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Private Benefit

501(c)(3)s must avoid all activities that will substantially benefit the private interest of any individual or organization.

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Inurement

No part of an organization’s net earnings may inure to the benefit of a private shareholder or individual. This means that a 501(c)(3) organization is prohibited from allowing its income or assets to accrue to insiders. The prohibition of inurement is absolute. Any amount will jeopardize the organization’s 501(c)(3) status.

20

Lobbying

Lobbying is an activity designed to influence legislation. If its lobbying activities are substantial, a 501(c)(3) may risk losing its tax-exempt status. The IRS uses two tests to determine whether lobbying is substantial: the substantial part test and the expenditure test.

21

Political Campaign Activity Political campaign activity involves

directly or indirectly participating or intervening in any political campaign on behalf of or in opposition to any candidate for elective office. The prohibition of political campaign activity is absolute. Any violation may result in the loss of tax-exempt status and the imposition of excise taxes.

22

Excessive Unrelated Business Income (UBI)

Unrelated Business Income Defined For most organizations, an activity is an

unrelated business (and subject to unrelated business income tax) if it meets three requirements: It is a trade or business, It is regularly carried on, and It is not substantially related to furthering

the exempt purpose of the organization.

http://www.irs.gov/charities/article/0,,id=96104,00.html 23

Size of the Untaxed Business Sector

Nonprofit institutions that serve households – most 501(c)(3) organizations, etc. – $483 billion (5.3% GDP) in 2002

State and local governments – $749 billion (8.2% GDP)

24Congressional Budget Office, Taxing the Untaxed Business Sector (July 2005), at 6,http://www.cbo.gov/doc.cfm?index=6567.

UBI Trade or business means selling goods or

services to generate income. Regularly carried on means the activity

shows frequency and continuity and that it is conducted in the same way that a non-exempt organization would run a similar business.

Not substantially related means that the activity is not important to furthering the exempt purpose of the organization (other than generating income for it).

http://www.stayexempt.irs.gov/Resource-Library/pdfs/Mod2_Summary.pdf 25

Exceptions to UBI

The Internal Revenue Code contains a number of exceptions to the usual rules of UBI. That means that some UBI is not subjected to tax. These exceptions include, but are not limited to, activities: Conducted by a volunteer workforce, Conducted for the convenience of

organizational members,

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Exceptions to UBI continued Involving the sale of donated

merchandise, Involving the distribution of low-cost

articles, Involving income from convention or

trade show participation, Involving income from qualified

sponsorship, and Traditional bingo.

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Exclusions and Deductions from UBI

In addition to the exceptions discussed, the Code allows certain other exclusions and deductions in calculating UBI tax.

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Exclusions

The exclusions include, but are not limited to, income generated from: Interest and dividends, Royalties, Certain rents from real properties with

the exception of income from debt-financed property, and

Certain gains and losses.

29

Deductions Allowable deductions include certain expenses,

depreciation, and similar items directly connected with carrying on an unrelated trade or business. In addition, other modifications allow for deductions like: The net operating loss deduction, where an

unrelated business loss in a previous or current tax year is deductible;

Charitable contributions made by the organization regardless of whether they are directly connected with the unrelated trade or business; and

The specific deduction that allows for $1,000 to be automatically deducted from the UBI tax calculation.

30

Charitable Gaming and Applicable Taxes A small amount of unrelated trade or business

activity in relation to an organization’s exempt purpose activity will have no impact on exempt status. Exempt status is only jeopardized when the activity generating unrelated income makes up a substantial part of the organization’s overall activities. Gaming is one of the most common and successful

types of fundraising. It can range from sponsoring a bingo game to a once-a-year raffle or casino night. Most often, gaming will generate UBI. Federal wagering excise taxes apply to certain types of gaming, but these taxes are typically not applicable to gaming conducted by 501(c)(3) organizations.

31

Filing Procedures for Form 990-T

Organizations with gross income of $1,000 or more from unrelated business must file Form 990-T annually.

Form 990-T is due the 15th day of the 5th month following the end of the organization’s accounting period.

32

UBIT Statistics

unrelated business income tax (UBIT) of $364.6 million reported by charities for 2004

Corporate entities made up 85 percent of the Form 990-T filing population and reported nearly 90% of total gross UBI

33http://www.irs.gov/pub/irs-soi/tehistory.pdf

Title XII of the Pension Protection Act of 2006

Detailed Summary of Charitable Provisions

http://waysandmeans.house.gov/media/pdf/taxdocs/072806charitable.pdf

Charitable Giving Incentives Charitable Reform

IRS, Pension Protection Act of 2006 Revises EO Tax Rules

http://www.irs.gov/charities/article/0,,id=161145,00.html

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Charitable Reform Provisions

Appraisal Reform Notification Requirement for Exempt

Organizations –Annual Notice 3 years to comply; revocation

Encourage IRS Information-Sharing with State Charity Officials

Public Disclosure of Information Relating to Unrelated Business Income Tax Returns

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Reactions to your Treasury’s recent reform proposal

General concerns about Nonprofits Specific Reactions to the proposal

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Concerns about Nonprofits: high salaries, high expenses IRS

e.g., OU Foundation’s Form 990, https://www.oufoundation.org/990.pdf

http://www.nytimes.com/2011/02/15/business/15charity.html

States e.g., Oklahoma Attorney General,

http://www.oag.state.ok.us/oagweb.nsf/0/0a9382d6ed29978f862572b400738e2f/$FILE/charityflier.PDF

37

Concerns about Nonprofits: high salaries, high expenses Charity watch groups, etc.

http://www.charitywatch.org/toprated.html http://liveunited.org/pages/accountability GuideStar. National directory of nonprofit

organizations, http://www2.guidestar.org/ Better Business Bureau. For Charities and

Donors. Includes evaluative reports on some national and regional charities. http://www.bbb.org/us/charity/

38

Concerns about Nonprofits:enriching related parties

Hospitals and trade associations use nonprofit status in ways that enrich doctors, etc.

Nonprofit, For-profit, and Government Hospitals: Uncompensated Care and Other Community Benefits (GAO-05-743T (2005), http://www.gao.gov/new.items/d05743t.pdf

State property tax exemption http://www.state.il.us/court/opinions/supremec

ourt/2010/march/107328.pdf

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Concerns about Nonprofits:tax evasion

IRS, Exempt Organization Tax Avoidance Transactions, http://www.irs.gov/charities/article/0,,id=128722,00.html

OECD, Report on Abuse of Charities for Money-Laundering and Tax Evasion (2009), http://www.oecd.org/dataoecd/30/20/42232037.pdf

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Treasury proposal: Scope of Unrelated Business

1. What should be the scope of a related business, unrelated business, primary purpose or non‑primary purpose test?

Reconsider the whole concept How much of your economy should go

untaxed? Passive income?

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Small-scale Threshold?

2. Should there be a small‑scale threshold, and if so, what would be the appropriate threshold?

3. Is there an alternative principle that could be used to provide a small‑scale or low‑risk activity exemption?

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Separate Entity Structure?

4. Would there be any unintended consequences resulting from any of these options?

5. Which option do you prefer and why?

6. Would we need to proceed with more than one option?

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Transition: Existing Activities 7. Would assistance be required to transition to the new

arrangements? 8. What costs will need to be borne by the entity? 9. What are the implications of longer versus shorter

transitional periods? 10. Would identification of the existing activity be by

reference to the overall business or to particular activities? 11. Should activities intended to be carried on or

contracted to enter into before 10 May 2011 be included? How would these be evidenced?

12. What should be the test for identifying new activities? 13. What is an acceptable time limit for allowing tax

concessions for existing government service delivery? Why?

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Tax Treatment of Entities Moving from Exempt to Taxable

14. Will the continuation of the ‘rule of books’ model in Division 57 in Schedule 2f of the ITAA 1936 achieve an appropriate transition from exemption to taxable status?

15. Are there any other factors to consider in transferring a taxable function or activity of an exempt entity to a separate entity?

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Getting back in the black

46Australian Government, Budget Overview (2011), at 8, http://cache.treasury.gov.au/budget/2011-12/content/download/Overview.pdf.

47

http://cboblog.cbo.gov/?p=2371

48Australian Government, Budget Overview, Budget Statement 1, at 1-13 (2011), http://cache.treasury.gov.au/budget/2011-12/content/download/bp1.pdf.

49Congressional Budget Office, The Long-Term Budget Outlook (June 2011), at 64, http://www.cbo.gov/doc.cfm?index=12212.

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Top 10 Income Tax Expenditures, 2012 (Billions)

Health insurance exclusion $184

Mortgage interest deduction 99

401(k) plans 68

Step-up of basis at death 61

Exclusion of net imputed rental income 51

Deductible nonbusiness state and local taxes other than on houses

49

Employer plans 45

Charitable contrib. (other than health & education) 43

Capital gains (except agriculture, timber, iron, coal) 38

Exclusion of interest on tax-exempt bonds 372012 Federal Budget, Analytical Perspectives, Chapter 17, Tax Expenditures, Table 17-3, http://www.whitehouse.gov/omb/budget/Analytical_Perspectives.

Recent Nonprofit Reform Proposals: Obama's Debt Panel

Option 1 (The "Zero Plan"): eliminate all tax expenditures or, alternatively, preserve only a few such tax benefits in exchange for higher marginal rates

Option 2: establish a 2% AGI floor Option 3: an across-the-board "haircut"

for all tax benefits if reform not enacted as of 2013

51http://lawprofessors.typepad.com/nonprofit/2010/11/obamas-debt-panel-and-tax-benefits-for-charities.html

Recent Nonprofit Reform Proposals, CBO

Congressional Budget Office, Options for Changing the Tax Treatment of Charitable Giving (2011), http://www.cbo.gov/ftpdocs/121xx/doc12167/CharitableContributions.pdf

Slides borrowed from a 15 June 2011 presentation by [email protected]

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Current Law Tax Treatment

Deductibility limited to only itemizers. Deduction subject to annual limits:

Total deductions: 50% of AGI Appreciated properties: 30% of AGI Contributions exceeding the limits may be

carried forward for up to 5 years. Starting in 2013: Pease provision

Itemized deduction reduced by 3% of AGI above a specific threshold. Total reduction is limited to 80% of the deduction.

53

Concerns About the Current Tax Treatment

(1) Could the tax subsidies be extended to more taxpayers without being too costly?

• Under current law, tax benefits only available for itemizers.

54

Concerns About the Current Tax Treatment

(2) Could the tax subsidies per dollar of giving be made more equal?

After-tax price of giving decreases with marginal tax rate. If facing T = 25%,

after-tax price of giving = $0.75.

If facing T = 10%, after-tax price of giving =

$0.90.55

Concerns: Concentration of Tax Subsidies Among High-Income Taxpayers

56

The 11 Policy Options

Reflecting 3 important characteristics: 1) whether the tax benefit includes a

floor 2) whether it is restricted to itemizers 3) whether it takes the form a deduction

or a credit.

57


Grouped into 4 categories: Retaining current deduction for itemizers but

adding a floor Allowing all taxpayers to claim the

deduction, with or without a floor Replacing the deduction with a 25% credit

for all taxpayers, with or without a floor Replacing the deduction with a 15% credit

for all taxpayers, with or without a floor

58


Two floors examined: $500 for single; $1000 for joint filers. 2% of AGI.

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Basis for the Estimates

Micro-simulation model 2006 Public-use sample of tax returns, 2007 CPS.

Impute nonitemizers’ charitable giving: SCF and CEX

All estimates are for tax year 2006. (The tax treatments are largely the same as those in 2011).

60

Caveats about the Estimates

Include only price effects (income effects are likely to very small).

Does not account for possible transformative changes that could lead to a major behavioral shift.

61

Price Elasticity Estimates from Selected Studies

Selected Empirical Studies Permanent Price Elasticity

Transitory Price Elasticity

Randolph (1995): 1979-1988 -0.51 -1.55

Auten et al. (2002): 1980-1992 -1.26 -0.40

Bakija, McClelland (2004): 1979-1990

-0.24 -0.40

Bakija, Heim (2011): 1979-2006 -1.10 -0.72

Experimental Method Overall Elasticity

Karlan, List (2007) -0.30

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Price Elasticity of Giving

Main Analysis: Assume Elasticity = -0.5

Sensitivity Analyses: Higher responses: Elasticity = -1.0 No response: Elasticity = 0

63

Effects on Donations and Tax Subsidies

The floor would allow the deduction to continue providing incentives but a much lower cost.

Floor for EligibleDonations

Keep Deduction Available Only to Itemizers but Add Floor

Option 1 $500/$1,000 202.5 -0.5 -0.2 35.4 -5.5 -13.5Option 2 2 percent of AGI 200.0 -3.0 -1.5 25.2 -15.7 -38.5

Change from Tax Subsidy Change from

PercentDollars Percent DollarsContributions Current-Law Level Current-Law Level

Total

64


Extending the deduction to all tax filers would be costly without a floor.


Extend Deduction to All Filers

Option 3 No floor 205.0 2.0 1.0 46.1 5.2 12.8Option 4 $500/$1,000 203.8 0.8 0.4 38.4 -2.5 -6.1Option 5 2 percent of AGI 201.1 -1.9 -0.9 27.8 -13.1 -32.1

Contributions Current-Law Level Current-Law LevelDollars Percent Dollars Percent

Total Change from Tax Subsidy Change from

65


However, combining this deduction with a floor could both raise donations and lower the tax cost - consistent with the finding by Ackerman and Auten (2006).

66


Similar pattern of results would occur if the itemizer deduction was replaced with a 25% credit.


Convert Deduction to 25 Percent Credit for All Filers

Option 6 No floor 205.7 2.7 1.3 48.0 7.1 17.4Option 7 $500/$1,000 204.5 1.5 0.7 38.5 -2.4 -5.8Option 8 2 percent of AGI 202.0 -1.0 -0.5 29.0 -11.9 -29.2



67


A small credit (e.g. 15% credit) would lower both donations and tax subsidy.


Convert Deduction to 15 Percent Credit for All Filers

Option 9 No floor 195.2 -7.8 -3.9 27.6 -13.3 -32.6Option 10 $500/$1,000 194.4 -8.6 -4.2 21.9 -19.0 -46.5Option 11 2 percent of AGI 193.0 -10.0 -4.9 16.3 -24.6 -60.1



68

Effects on Various Income Groups Comparing

Tax Subsidy Rate (= Tax Subsidy/AGI) under current law and under a given policy change.

69

Effects on Various Income Groups Extending

tax benefits to all filers would mostly benefit lower- and middle-income taxpayers.

70

Effects on Various Income Groups Adding a floor

would lower tax subsidies across the board.

High-income taxpayers are significantly worse off under the 2% of AGI floor.

71

Sensitivity Analysis: Alternative Elasticity Values

Two alternative assumptions: Zero elasticity Elasticity of -1.0

Main results still hold. Adding a floor would lower revenue cost

significantly with moderate effects on giving.

Extending tax subsidies to all filers without a floor is very costly.

72

Sensitivity Analysis: Alternative Elasticity Values

Option 3--Deduction for All Taxpayers with No Floor

Elasticity of 0 (Not responsive) 203.0 0 0 45.6 4.7 11.5Elasticity of -0.5 205.0 2.0 1.0 46.1 5.2 12.8Elasticity of -1.0 207.4 4.4 2.2 46.7 5.8 14.3

Option 4--Deduction for All Taxpayers with $500/$1000 Floor

Elasticity of 0 (Not responsive) 203.0 0 0 38.2 -2.7 -6.7Elasticity of -0.5 203.8 0.8 0.4 38.4 -2.5 -6.1Elasticity of -1.0 204.9 1.9 0.9 38.7 -2.2 -5.4

Dollars PercentContributions Current-Law Level Current-Law Level

Dollars Percent


73

Sensitivity Analysis: Possible Retiming of Donations

A floor creates an incentive to bunch contributions.

Example: a family with annual giving of $3000 Assume a floor of $1000 No bunching: $2000 eligible for tax subsidy Bunch in alternating years: Year 1 gives

$6000, Year 2 gives 0. $2500 eligible for tax subsidy (averaged

amount over 2 years).

74

Sensitivity Analysis: Possible Retiming of Donations

A floor still reduce the tax revenue cost significantly, with relatively modest effects on total giving.

Option 5--Deduction for All Taxpayers with 2% of AGI Floor

No retiming of contributions 201.1 -1.9 -0.9 27.8 -13.1 -32.1Contributions bunched in alternate years 203.3 0.3 0.1 34.5 -6.4 -15.7

PercentDollars Percent Dollars

Total Change from Tax Subsidy Change fromContributions Current-Law Level Current-Law Level

75

Some Key IRS Resources Internal Revenue Service, Tax Information for Charities &

Other Non-Profits web page, http://www.irs.gov/charities/index.html?navmenu=menu1

Forms and Instructions for Exempt Organizations Links to current tax forms for tax-exempt organizations, http://www.irs.gov/charities/article/0,,id=214269,00.html

Form 990 Resources and Tools Educational materials about EO annual return filings, http://www.irs.gov/charities/article/0,,id=214479,00.html

IRS Stay Exempt: Tax Basics for Exempt Organizations, http://www.stayexempt.irs.gov/Home.aspx

76

More IRS Resources Stay Exempt (Course Summary: Unrelated

Business Income), http://www.stayexempt.irs.gov/Resource-Library/pdfs/Mod2_Summary.pdf

Unrelated Business Income Tax - Special Rules for Organizations Exempt Under Code Section 501(c)(7), 501(c)(9), 501(c)(17), or 501(c)(20), http://www.irs.gov/charities/article/0,,id=96106,00.html

Publication 598, Tax on Unrelated Business Income of Exempt Organizations

Unrelated Business Income Tax Course, http://www.stayexempt.irs.gov/virtualworkshop/UnrelatedBusinessIncome.aspx

77

More Resources Roger Colinvaux, Charity in the 21st Century: Trending

Toward Decay (2011), http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1809171

Molly F. Sherlock & Jane G. Gravelle, An Overview of the Nonprofit and Charitable Sector (2009), http://www.fas.org/sgp/crs/misc/R40919.pdf

Joint Committee on Taxation, Historical Development And Present Law Of The Federal Tax Exemption For Charities And Other Tax-Exempt Organizations (2005), http://www.jct.gov/publications.html?func=startdown&id=1586

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More Resources Senate Finance Committee Hearing on Charity Oversight

and Reform (Congressional Research Service Report No. R40919, June 22, 2004), http://finance.senate.gov/hearings/hearing/?id=48ca4cce-afe1-db95-0fcb-8ff9255e780a

Nonprofit Law Prof Blog, http://lawprofessors.typepad.com/nonprofit/

National Center on Philanthropy and the Law (NCPL), http://www1.law.nyu.edu/ncpl/ Conferences:

Shades of Virtue: Measuring the Comparative Worthiness of Charities (2009)(Published Proceedings forthcoming 2011)

Structures at the Seam: The Architecture of Charities’ Commercial Activities (2008)

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About the Author Jonathan Barry Forman (“Jon”) is the Alfred P.

Murrah Professor of Law at the University of Oklahoma College of Law and the author of Making America Work (Washington, DC: Urban Institute Press, 2006).

Jon was the Professor in Residence at the Internal Revenue Service Office of Chief Counsel, Washington, DC, for the 2009-2010 academic year.

Jon can be reached at [email protected], 405-325-4779, www.law.ou.edu/faculty/forman.shtml.

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An American Perspective on Not-for-Profit Tax Concessions

Documents

charitable organizations

existing public charities

public charityduring

general public

life cycle

tax year

federal income tax

recent tax reform proposals