Upon completion of this course, participants will be able to:

• Differentiate between various types of NPOs and the specific tax exemptions applicable to each.
• Analyze the criteria and process for obtaining and maintaining tax-exempt status (e.g., public benefit test).
• Apply the Unrelated Business Income Tax (UBIT) rules to determine taxability of NPO commercial activities.
• Understand the specific tax rules governing private foundations and public charities.
• Advise NPOs on donor substantiation requirements and the deductibility of charitable contributions.
• Identify prohibited political and legislative activities that jeopardize tax-exempt status.
• Master the unique filing and reporting requirements for NPOs (e.g., annual information returns).
• Analyze the tax implications of NPO mergers, joint ventures, and international operations.

• Accountants and Auditors serving Non-Profit Clients
• Legal Counsel and Lawyers specializing in Non-Profit Law
• Executive Directors and CFOs of Charities and Foundations
• Tax Compliance and Audit Staff specializing in NPOs
• Financial Managers of Educational and Healthcare Institutions
• Fundraising and Development Professionals
• Consultants specializing in Governance and NPO Regulation

• Case studies on determining UBIT for hypothetical NPO revenue streams (Group Activity).
• Legal analysis of a tax court decision on revocation of exempt status (Individual Exercise).
• Role-playing: Advising a board on the tax risks of a new commercial venture.
• Workshop on correctly completing key sections of the annual information return.
• Discussions on the ethical line between advocacy and prohibited political intervention.

Unit 1: Tax-Exempt Status and Qualifications

• The policy rationale for granting tax exemption to certain organizations
• Distinguishing between different types of tax-exempt entities (e.g., religious, charitable, social welfare)
• The process for applying for and obtaining exempt status (e.g., application forms, criteria)
• Grounds for revocation of tax-exempt status and appeal procedures

• Defining the "public support test" for public charities
• The special tax rules, excise taxes, and restrictions applicable to private foundations
• Managing grant-making and expenditure responsibility requirements

Unit 2: Unrelated Business Income Tax (UBIT)

• The rationale for taxing NPO commercial activities (level playing field argument)
• Defining Unrelated Business Income (UBI): trade or business, regularly carried on, not substantially related
• Common exceptions to UBIT (e.g., passive income, volunteer work, research income)

• Determining deductible expenses and calculating net UBI
• Applying the rules for debt-financed income (Unrelated Debt-Financed Income)
• Filing requirements and tax rates for UBIT

Unit 3: Contributions and Donor Rules

• Donor requirements for charitable contribution deductions (e.g., substantiation)
• Rules for *quid pro quo* contributions and valuing benefits received by donors
• Limitations on the deductibility of appreciated property and complex gifts

• Tax disclosure requirements for fundraising solicitations
• Reporting requirements for large gifts and non-cash contributions
• Managing planned giving vehicles (e.g., charitable trusts, annuities)

Unit 4: Compliance and Governance

• Mastering the annual information return (e.g., Form 990) and its schedules
• Public disclosure requirements for NPO financial information
• Penalties for failure to file or providing incomplete/inaccurate returns

• Prohibition on private inurement and private benefit
• Rules regarding excess benefit transactions and intermediate sanctions
• Conflicts of interest and responsible governance structures

Unit 5: NPOs and the Broader Economy

• The specific limits on political campaign intervention for 501(c)(3) organizations
• Measuring and managing lobbying expenditures and permissible limits

• Taxation of foreign NPOs operating domestically and vice versa
• Tax implications of joint ventures between NPOs and for-profit entities