The Tax Law of Charitable Giving. Bruce R. Hopkins

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The Tax Law of Charitable Giving - Bruce R. Hopkins


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the profit motive and offers the consumer the “trust element” that the for-profit organizations cannot always provide.

      Tax exemption for nonprofit membership organizations may be viewed as a manifestation of the constitutionally protected right of association accorded the members of these organizations. There are two types of freedom of association. One type—termed the freedom of intimate association—is the traditional type of protected association derived from the right of personal liberty. The other type—the freedom of expressive association—is a function of the right of free speech protected by the First Amendment to the U.S. Constitution.


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