Overview

Stay current with rapidly evolving tax-exempt regulations and emerging issues The 2026 Supplement to the 13th edition of The Law of Tax-Exempt Organizations updates and expands this authoritative resource with the most recent statutes, regulations, rulings, and court opinions affecting nonprofit organizations. Compiled by renowned authors and legal experts Bruce R. Hopkins and Shane Hamilton, this supplement maintains the accessible language and clear analysis that professionals have relied upon, while addressing the critical developments that have emerged since the 13th edition's publication. The supplement is accompanied by updated online resources, including the latest IRS Private Letter Rulings, Technical Advice Memoranda, and Counsel Memoranda, as well as new reference materials reflecting recent regulatory changes. Key topics covered in this supplement include: Artificial intelligence applications in nonprofit operations, including governance considerations, compliance obligations, and ethical deployment frameworks Recent legislative changes affecting charitable giving, donor reporting requirements, and tax incentives for charitable contributions Evolving standards for nonprofit governance in response to heightened regulatory scrutiny and best practices in board oversight Developments in tax-exempt status determinations, including new IRS guidance on mission-related activities and unrelated business income Cybersecurity and data protection requirements for tax-exempt organizations handling sensitive donor and constituent information Updated provisions affecting religious organizations, educational institutions, healthcare entities, and social welfare organizations Tax-exempt law continues to evolve with unprecedented speed, driven by legislative action, regulatory guidance, and emerging operational challenges. The 2026 Supplement to The Law of Tax-Exempt Organizations provides nonprofit leaders, boards, and compliance professionals with essential updates to ensure their organizations remain current and compliant with all applicable statutes, regulations, and best practices.

Full Product Details

Author:   Shane T. Hamilton (Meadows Mental Health Policy Institute for Texas) ,  Bruce R. Hopkins (District of Columbia Bar)
Publisher:   John Wiley & Sons Inc
Imprint:   John Wiley & Sons Inc
Edition:   13th edition
ISBN:  

9781394354337

ISBN 10:   1394354339
Pages:   368
Publication Date:   05 May 2026
Audience:   Professional and scholarly ,  Professional & Vocational
Format:   Paperback
Publisher's Status:   Forthcoming
Availability:   Awaiting stock  

Table of Contents

About the Author xiii Preface xv Book Citations xix 1 Definition of and Rationales for Tax-Exempt Organizations 1 § 1.2 Definition of Tax-Exempt Organization 1 § 1.4 Political Philosophy Rationale 1 2 Overview of Nonprofit Sector and Tax-Exempt Organizations 3 § 2.1 Profile of Nonprofit Sector 3 § 2.2 Organization of IRS 4 3 Tax Exemption: Source and Recognition 5 § 3.3 Recognition of Public Charity, Private Foundation Status 5 4 Organizational, Operational, and Related Tests and Doctrines 7 § 4.3 Organizational Test 7 § 4.4 Substantial Nonexempt Purposes 10 § 4.5 Operational Test 23 § 4.6 Feeder Organizations 26 § 4.7 Commensurate Test 29 § 4.9 Commerciality Doctrine 30 5 Nonprofit Governance 35 § 5.3 Board Duties and Responsibilities 35 6 Concept of Charitable 37 § 6.2 Public Policy Doctrine 37 § 6.3 Collateral Concepts 38 7 Charitable Organizations 43 § 7.2 Relief of Distressed 43 § 7.3 Credit Counseling 44 § 7.6 Promotion of Health 44 § 7.13 Consortia 47 § 7.14 Fundraising Organizations 47 § 7.15 Government Entities as Charitable Counterparts 48 § 7.16 Other Categories of Charity 49 § 7.18 Charitable Grants to Individuals 49 8 Educational Organizations 51 § 8.3 Educational Institutions 51 § 8.4 Instruction of Individuals 51 § 8.5 Instruction of Public 52 9 Scientific Organizations 53 § 9.5 Technology Transfer 53 10 Religious Organizations 55 § 10.1 Constitutional Law Framework 55 § 10.3 Churches and Similar Institutions 55 § 10.8 Apostolic Organizations 56 11 Other Types of Charitable Organizations 57 § 11.2 Amateur Sports Organizations 57 § 11.6 Charitable Risk Pools 57 12 Public Charities and Private Foundations 59 § 12.1 Federal Tax Law Definition of Private Foundation 59 § 12.3 Categories of Public Charities 59 § 12.5 Donor-Advised Funds 59 § 12.6 Endowment Funds 60 13 Social Welfare Organizations 65 § 13.1 Concept of Social Welfare 65 § 13.2 Requirement of Community 65 § 13.3 Conduct of Business 66 § 13.4 Advocacy Organizations 67 14 Business Leagues and Similar Organizations 69 § 14.1 Concept of Business League 69 § 14.2 Disqualifying Activities 70 § 14.3 Chambers of Commerce 70 15 Social Clubs 71 § 15.1 Social Clubs in General 71 § 15.2 Public Use and Investment Income Limitations 73 § 15.3 Exception to Limitations for Unusual Amounts 76 16 Labor, Agricultural, and Horticultural Organizations 79 § 16.1 Labor Organizations 79 17 Political Organizations 81 § 17.4 Public Policy Advocacy Activities 81 18 Employee Benefit Funds 83 § 18.3 Voluntary Employees' Beneficiary Associations 83 19 Other Categories of Tax-Exempt Organizations 85 § 19.5 Benevolent or Mutual Organizations 85 § 19.6 Cemetery Companies 85 § 19.18 Qualified Health Insurance Issuer 86 § 19.19 Qualified Tuition Programs 86 § 19.20 ABLE Programs 87 § 19.22 Governmental and Quasi-Governmental Entities 87 § 19.23 Native American Tribes 88 20 Private Inurement and Private Benefit Doctrines 89 § 20.1 Concept of Private Inurement 89 § 20.4 Compensation Issues 89 § 20.5 Excess Executive Compensation Tax 90 § 20.6 Other Forms of Private Inurement 92 § 20.8 Incidental Private Inurement 92 § 20.12 Private Inurement and Other Categories of Exempt Organizations 92 § 20.13 Private Benefit Doctrine 93 21 Intermediate Sanctions 95 § 21.2 Tax-Exempt Organizations Involved 95 § 21.3 Disqualified Persons 95 § 21.4 Excess Benefit Transactions 95 § 21.10 Excise Tax Regime 96 § 21.14 Return for Payment of Excise Taxes 96 22 Legislative Activities by Tax-Exempt Organizations 99 § 22.3 Lobbying by Charitable Organizations 99 § 22.4 Lobbying Expenditures and Tax Sanctions 100 § 22.5 Legislative Activities of Social Welfare Organizations 100 § 22.6 Legislative Activities of Business Leagues 100 § 22.7 Legislative Activities of Other Exempt Organizations 100 23 Political Campaign Activities by Tax-Exempt Organizations 101 § 23.1 Introduction 101 § 23.2 Prohibition on Charitable Organizations 102 § 23.3 Political Campaign Expenditures and Tax Sanctions 102 § 23.6 Political Activities of Social Welfare Organizations 103 § 23.10 Advocacy Communications 106 24 Unrelated Business: Basic Rules 107 § 24.1 Introduction to Unrelated Business Rules 107 § 24.5 Contemporary Applications of Unrelated Business Rules 108 § 24.9 Commercial-Type Insurance 108 25 Unrelated Business: Modifications, Exceptions, Special Rules, and Taxation 109 § 25.2 Exceptions 109 § 25.5 “Bucketing” Rule 110 26 Exemption Recognition and Notice Processes 111 § 26.1 Recognition Application Procedure 111 § 26.2 Requirements for Charitable Organizations 116 § 26.3 Nonprivate Foundation Status 116 § 26.4 Requirements for Social Welfare Organizations 116 § 26.5 Requirements for Certain Credit Counseling Organizations 117 § 26.6 Requirements for Certain Employee Benefit Organizations 117 § 26.8 Requirements for Certain Health Insurance Issuers 117 § 26.10 Rules for Other Categories of Organizations 117 § 26.11 Group Exemption Rules 117 § 26.12 Terrorism-Related Suspension of Tax Exemption 118 § 26.13 Notice Requirements for Social Welfare Organizations 118 § 26.14 Notice Requirements for Political Organizations 119 § 26.15 Integral Part Doctrine 119 § 26.16 Forfeiture of Tax Exemption 119 27 Administrative and Litigation Procedures 121 § 27.1 Administrative Procedures Where Recognition Denied 121 § 27.2 Revocation or Modification of Tax-Exempt Status: Administrative Procedures 122 § 27.3 Retroactive Revocation of Tax-Exempt Status 122 § 27.5 Denial or Revocation of Tax-Exempt Status: Litigation Procedures 123 § 27.6 IRS Examination Procedures and Practices 124 § 27.8 Fast-Track Case Settlement Program 126 § 27.9 IRS Disclosure to State Officials 126 28 Operational Requirements 127 § 28.1 Changes in Operations or Form 127 § 28.2 Annual Reporting Rules 129 § 28.4 Automatic Revocation for Failure to File 129 § 28.5 Charitable Organization Listing Reliance Rules 130 § 28.8 Unrelated Business Income Tax Returns 130 § 28.9 Document Disclosure Obligations of IRS 130 § 28.10 Document Disclosure Obligations of Exempt Organizations 130 § 28.11 Information or Services Disclosure 135 § 28.12 Fundraising Disclosure 135 § 28.13 Insurance Activities 135 § 28.14 Feeder Organizations 135 § 28.16 Tax-Exempt Organizations and Tax Shelters 135 29 Tax-Exempt Organizations and Exempt Subsidiaries 147 § 29.1 Subsidiaries Basics 147 30 Tax-Exempt Organizations and For-Profit Subsidiaries 149 § 30.6 Revenue from For-Profit Subsidiary 149 § 30.7 Liquidations 149 31 Tax-Exempt Organizations and Joint Ventures 151 § 31.1 Partnerships and Joint Venture Basics 151 § 31.4 Ancillary Joint Ventures 151 32 Tax-Exempt Organizations: Other Operations and Restructuring 153 § 32.7 Conversion from Nonexempt to Exempt Status 153 About the Online Resources 157 Appendix A - Sources of Tax-Exempt Organizations Law 159 Appendix B - Internal Revenue Code Sections 181 Appendix C - Categories of Tax-Exempt Organizations 193 Table of Cases 197 Table of IRS Revenue Rulings 243 Table of IRS Revenue Procedures 263 Table of IRS Determinations Cited in Text 265 Table of Other IRS Determinations 293 Cumulative Index 325

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