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Private and Corporate Philanthropy

Practices

Foundation & Exempt Organization Matters

Our Foundations and Exempt Organizations group assists clients in establishing and effectively operating nonprofit tax-exempt organizations including community foundations, private foundations, publicly supported charities, trade associations and taxable nonprofit entities.

We advise clients on:

  • Tax and corporate planning for nonprofit organizations
  • Formation of nonprofit entities
  • Qualification of nonprofit entities for tax-exempt status
  • Conversions to and from exempt status
  • Structuring of joint ventures with for-profit entities
  • Formation of LLCs among nonprofit and for-profit organizations
  • Corporate reorganizations and liquidations, including reorganizations of hospitals, arts organizations, museums, foundations and other exempt organizations
  • Restructuring an exempt organization by forming a holding company, operating subsidiaries and taxable subsidiaries to align the corporate structure with the business objectives and shield the tax exemption for the organization from growing for-profit lines of business.
  • Creating a fundraising foundation for a tax-exempt operating charity.
  • Structuring the private use of a tax-exempt financed facility to comply with private use bond restrictions and avoid unrelated business income on certain uses.
  • Negotiating and handling all aspects of the affiliation of a local hospital with a larger health care system.
  • Assisting a corporate private foundation in creating and expanding programs that address charitable initiatives of its domestic and foreign employees.
  • Developing a joint venture between a tax-exempt charity and a for-profit corporation for the operation of a new initiative of the charity in a new geographic location.
  • Forming supporting organizations to a large tax-exempt institution to allow it to accept complex interests in other business entities as a charitable gift.
  • Converting a for-profit home health care agency to a nonprofit entity and operation.
  • Assisting a tax-exempt organization in implementing a strategic plan, including the consolidation of operations, the development of new operations and formation of other related entities, and a change in status for federal tax-exempt purposes.
  • Structuring an LLC involving a tax-exempt charity and for-profit entities for the undertaking of educational operations for the tax-exempt charity intended to qualify as a charitable activity.