While listed as private, are they for insiders’ benefit only?
Many types of organizations that are tax-exempt under Code Section 501(a) must be organized so that no part of the net earnings of the organization inure to the benefit of any private shareholder. Organizations that are tax-exempt under Code Section 501(c)(3) must also be organized and operated exclusively for charitable purposes, which can raise the issue regarding whether the organization operates for public, rather than private benefit. This white paper reviews private inurement and private benefit and case law rulings.
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