Preface ix Part I Qualifications of Tax-Exempt Organizations 1 Chapter 1 Distinguishing Characteristics of Tax-Exempt Organizations 3 § 1.8 Developments Responding to COVID-19 Chapter 2 Qualifying Under IRC § 501(c)(3) 11 § 2.2 Operational Test Chapter 3 Religious Organizations 19 § 3.2 Churches Chapter 4 Charitable Organizations 23 § 4.1 Relief of the Poor § 4.3 Lessening the Burdens of Government § 4.5 Advancement of Education and Science § 4.6 Promotion of Health Chapter 5 Educational, Scientific, and Literary Purposes and Prevention of Cruelty to Children and Animals 29 § 5.

1 Educational Purposes Chapter 6 Civic Leagues and Local Associations of Employees: § 501(c)(4) 31 § 6.2 Qualifying and Nonqualifying Civic Organizations Chapter 9 Social Clubs: § 501(c)(7) 35 § 9.4 Revenue Tests Chapter 11 Public Charities 37 § 11.2 "Inherently Public Activity" and Broad Public Support: § 509(a)(1) § 11.5 Difference Between § 509(a)(1) and § 509(a)(2) Part II Standards For Private Foundations 39 Chapter 12 Private Foundations--General Concepts 41 § 12.4 Termination of Private Foundation Status Chapter 14 Self-Dealing: IRC § 4941 43 § 14.2 Sale, Exchange, or Lease of Property § 14.5 Transactions That Benefit Disqualified Persons Chapter 15 Minimum Distribution Requirements: IRC § 4942 45 § 15.

1 Assets Used to Calculate Minimum Investment Return § 15.2 Measuring Fair Market Value § 15.4 Qualifying Distributions Chapter 16 Excess Business Holdings and Jeopardizing Investments: IRC §§ 4943 and 4944 51 § 16.1 Excess Business Holdings § 16.2 Jeopardizing Investments Chapter 17 Taxable Expenditures: IRC § 4945 53 § 17.3 Grants to Individuals § 17.4 Grants to Public Charities Part III Obtaining and Maintaining Tax-Exempt Status 59 Chapter 18 IRS Filings, Procedures, and Policies 61 § 18.1 IRS Determination Process § 18.

2 Annual Filing of Form 990 § 18.4 Weathering an IRS Examination Chapter 19 Maintaining Exempt Status 77 § 19.1 Checklists Chapter 20 Private Inurement and Intermediate Sanctions 85 § 20.11 New § 4960 Excise Tax on Excess Compensation Chapter 21 Unrelated Business Income 89 § 21.4 Definition of Trade or Business § 21.8 Unrelated Activities § 21.10 Income Modifications § 21.11 Calculating and Minimizing Taxable Income Chapter 23 Electioneering and Lobbying 95 § 23.

3 Tax on Political Expenditures Chapter 24 Deductibility and Disclosures 99 § 24.1 Overview of Deductibility § 24.2 The Substantiation and Quid Pro Quo Rules § 24.3 Valuing Donor Benefits Chapter 25 Employment Taxes 105 § 25.1 Distinctions Between Employees and Independent Contractors Index 111.