Karl Mill Karl Mill

Yet More 501(c)(3) Denials: Multilevel Marketing Edition

There are times when I read over the most recent batch of IRS 501(c)(3) denial rulings and shed a tear (figuratively speaking, of course) for the shattered dreams of well-intentioned but misguided applicants. This is not one of those times.

There was a batch of six IRS denial rulings that came across my desk, and I will probably cover at least a few of the other five eventually. But my penchant for schadenfreude drew me to the one that mentioned blatant partisan campaign intervention and prohibited benefits to a multi-level marketing company. And honestly, it’s much worse than that.

Let’s do a quick recap as an excuse to cover these two issues, one of which is as “black-and-white” as they come (electioneering) while the other (managing private benefit so that a relationship to an affiliated for-profit does not cost the 501(c)(3) its exempt status) is typically a very gray area and one that we spend a lot of time talking to clients about in order to get the balance right. But, honestly, I just wanted to share some insane facts.

Read More
Karl Mill Karl Mill

Deciphering Impact Investment acronyms: UPMIFA, UBIT, PRI, and MRI

Where there is money, there are lawyers and consultants. And where there are lawyers and consultants, there are acronyms, deployed like they are words that everyone knows.

There is a lot of money flowing around the impact investment sector. Therefore, it can be very easy for non-profits, and especially private foundations, to get lost in a sea of letters when they want to invest in a manner that advances their charitable purposes. There’s only so much a blog post can do, but let’s see if we can unpack four of the big acronyms.

Read More