On July 14, 2023, the IRS issued Technical Guide 3-10 for Disqualifying and Non-Exempt Activities – Trade or Business Activities – IRC Section 501(c)(3). The TG 3-10 discusses the “fragmentation” of nonprofit and for-profit business models that may be engaged by tax-exempt organizations. And, TG 3-10 dovetails quite neatly with the below-linked three-part Freeman Law Insights series that I published in 2022 on unrelated business income tax matters affecting tax-exempt organization. See and compare TG 3-10 with prior Freeman Law Insights post, Tax Exemption and Unrelated Business Income Rules (UBIT): “Substantially Related” (Part 3 of 3).

All really solid resources. Taken together, these resources provide valuable insight in this complex area of the tax-exempt space.

IRS Technical Guidance

• Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941
• Exempt Organizations Technical Guide TG 62 Excise Taxes on Taxable Expenditures
• TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and TG 3-3 Exempt Purpose, Charitable IRC 501(c)(3)
• Exempt Organizations Technical Guide TG 6 IRC 501(c)(6) Business League

Nonprofit and Exempt Organization Attorneys

Every nonprofit is different, that’s why we collaborate with our nonprofit clients to identify and meet their unique needs. Freeman Law represents associations & 501(c)(6) organizations, churches and other religious organizations, foundations, private foundations, 501(c)(3) organizations, and other nonprofit clients. While nonprofits encounter many of the same economic concerns and administrative challenges as any business, they also face many unique challenges.