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Abstract: 

The IRS continues to issue rulings denying tax-exempt status to organizations pursuing exemption. These rulings highlight issues that prevent an organization from obtaining exemption. Practitioners should take care to avoid these problems when setting up new IRC §501(c)(3) organizations. Our review of Private Letter Rulings suggest that organizations avoid lobbying as a substantial purpose (PLR 201908024); avoid substantial private benefit (PLR 201831013); be alert to the “optics” of an application (PLR 201921019); and make sure the beneficiaries constitute a charitable class (PLR 201923026, PLR 201907014, and PLR 201911008).

Keywords: Private Letter Rulings; Exempt Status Denials

Affiliations:  1: Clark Hill Strasburger.