Tax-Exempt Organizations

We have maintained an extensive practice over the past 40 years representing tax-exempt organizations, including particularly universities and their related medical centers, public and private charitable organizations and religious organizations. We have assisted in the formation of new charitable organizations and trade associations; the reorganization of academic medical centers and other exempt organizations; the formation, funding and expansion of business subsidiaries of exempt organizations; the litigation of unrelated business income tax controversies; planning to minimize unrelated business income tax liabilities; the legislative consideration of modifying current unrelated business income tax laws; negotiation of employment contracts and fringe benefit arrangements; the utilization of self-insurance trusts and captive insurance companies for medical malpractice and general liabilities; both the acquisition and divestiture of non-profit hospitals by various clients; compliance with private foundation restrictions and regulations; and the tax-exempt financing of various hospital and university capital projects.

Examples of our continuing tax-exempt clients include the American Council on Education, Duke University, Emory University, the Dartmouth-Hitchcock Medical Center, the American Bar Endowment, the Carnegie Corporation of New York, the University of Iowa, the New England Alumni Trust and the Southeastern Council of Foundations. In addition to these and other continuing clients, we have in recent years undertaken special projects for numerous other exempt organizations, including the Fort Sanders Alliance and Fort Sanders Regional Medical Center (Knoxville, Tennessee), the Commission on College Retirement, MetroHealth Foundation, Group Health Plan, Harvard, Stanford and Southern Methodist Universities and the Universities of Texas and North Carolina. Our exempt organization clients are based throughout the United States and in several foreign jurisdictions, including Bermuda and Switzerland.

A number of our lawyers spend a substantial portion of their time on matters involving tax-exempt organizations. One of our partners is a past chair of the Committee on Exempt Organizations of the ABA Section of Taxation and is a member of the IRS Exempt Organizations Advisory Group.