IRS Issues Exempt Organizations Technical Guide For Disqualifying And Non-Exempt Activities For 501(c)(3) Organizations

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.