Tax-Exempt Organizations

A Focused Practice With Depth

Chambers USA (2019) praises us for our “focus and depth within the tax-exempt sector.” We have decades of experience advising nonprofit corporations and charitable trusts on tax matters, including Texas Children’s Hospital on a variety of governance, transaction and finance matters; the Texas Medical Center on tax issues related to the development of the TMC3 campus; and a number of significant private foundations, including Houston Endowment Inc., The Brown Foundation and the T.L.L. Temple Foundation, on tax issues of particular importance to private foundation.

Our team is highly regarded for its experience and knowledge of complex tax rules and regulations, such as:

• the private inurement proscription
• the private benefit limitation
• section 501(r) compliance for hospitals
• excise taxes applicable to private foundations
• section 4958 (intermediate sanctions) compliance
• lobbying and electioneering rules
• structuring investments to avoid unrelated business income tax
• IRS examinations and rulings
• tax-exempt finance

In addition, we provide legal guidance to nonprofit corporations in connection with a variety of business transactions, such as mergers and acquisitions, sales and purchases of physician practices and debt offerings. We also advise tax-exempt organizations on corporate governance matters, helping them draft and interpret governance documents and policies, as well as negotiating gift and naming rights agreements with donors.

Our clients include hospitals and healthcare organizations, senior living facilities, colleges and universities, independent and parochial schools, museums and arts organizations, conservation organizations, advocacy groups, student loan organizations, grant-making foundations and charitable trusts.