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A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
Evelyn Brody
This piece, included in the University of Hawaii Law Review's symposium issue on the Bishop Estate, explores the relationship between the new intermediate sanctions law and the IRS's power to revoke tax exemption under § 501(c)(3). Inspired by the storied setting, I indulge in a fantasy: This article pretends that the IRS revoked the Estate's exemption, and takes the form of the Tax Court declaratory judgment opinion. I reluctantly 'rule' that exemption was not appropriate, because State enforcement action against the trustees was proceeding. (However, this forum allows me to hedge my argument by producing two concurring and one dissenting …
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
Evelyn Brody
No abstract provided.
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
Evelyn Brody
This piece explores the broad financial relationship between the public and the charitable sectors. Tax exemption operates as a peculiar subsidy - offering the greatest benefits to charities carrying on the most profitable activities and owning the most valuable property. Perhaps, then, the property tax and income tax exemption of charities can be explained by a 'sovereign' view of the charitable sector. Resembling the federal tax treatment of state and local governments, exemption for charities respects the independence of the nonprofit sector, and minimizes the involvement of charities in the political process. Unfortunately, the long history of Anglo American philanthropy …
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
Evelyn Brody
No abstract provided.