Tax Exempt Organizat ...

Tax Exempt Organizations

Helping form, build and maintain nonprofit efforts

Butler Snow’s dedicated group of tax attorneys have extensive experience with tax-exempt organizations. We’re here to help with the specific challenges nonprofits face, whether those matters are routine or highly complex.

We represent clients in a wide array of areas, such as healthcare, including medical research facilities, clinics and hospitals; education-focused organizations, including universities and other facilities; charitable causes of all types; and faith-based organizations; as well as many others.

Our tax attorneys provide legal services to tax-exempt entities that include organizing non-profit organizations and assisting them in applying for and maintaining tax-exempt status. We also provide legal guidance to tax-exempt entities regarding private inurement issues, unrelated business income tax issues, tax-exempt intermediate sanctions, joint venture transactions with for-profit and non-profit organizations, and other related issues.

As with many other practice areas within our firm, our tax-exempt practice group often interacts with several other practice areas, such as real estate or estate planning. As a full-service law firm with a collaborative culture, our tax-exempt clients can expect a full-picture solution to their legal concerns.


  • Representation of numerous 501(c)(3) public charities and private foundations with respect to formation, application for tax-exempt status, and ongoing corporate governance and compliance matters.
  • Representation of a nonprofit hospital in various corporate governance and compliance matters and drafting and negotiating various service provider, employment, lease and clinical affiliation agreements related to hospital operations.
  • Regularly provide counsel to clients on tax-efficient cross-border charitable giving, including through the use of U.S. ‘friends of’ organizations and ‘dual qualified’ charities.
  • Regularly provide counsel to clients on tax-efficient giving, including through personal philanthropic vehicles, and provide advice on creating and operating U.S. tax-exempt public charities and private foundations.
  • Representation of a corporation owning and operating a professional sports franchise in obtaining federal tax-exempt status.
  • Representation of charter school corporations and private schools in obtaining tax-exempt status.
  • Representation of individuals in obtaining federal tax-exempt status for establishing a university, hospital and primary/secondary school in an underdeveloped country.
  • Representation of tax-exempt organizations in protecting and enhancing executive talent by obtaining private letter ruling for phantom stock plan for executives with for-profit subsidiary.
  • Representation of a quasi-governmental entity in conversion to charitable 501(c)(3) status and provided tax-exempt counsel in the merger of two charitable organizations.
  • Representation of large tax-exempt organizations as they created umbrella holding organizations with charitable and for-profit subsidiaries and separate management companies.
  • Representation of an organization believed to be tax-exempt for over 10 years, that was ultimately determined to be not exempt, in successful special IRS appeal directly to the district director to obtain retroactive exemption.