The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement. Bruce R. Hopkins

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The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement - Bruce R. Hopkins


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In that year, there were 1,088,447 registered public charities, of which 314,744 were sufficiently large to file Form 990.66.3 These organizations reported $3.8 trillion in total assets ($2.3 trillion in net assets) and total revenue of $2 trillion (approximately 11 percent of gross domestic product). Most of the Form 990 filers were relatively small (assets of less than $500,000) or medium‐sized (assets of $500,000 up to $10 million) charities (41.2 percent and 47.2 percent, respectively). The larger organizations, those with at least $10 million in assets, were 11.6 percent of Form 990 filers; 93.1 percent of assets were held by, 87.1 percent of revenues were received by, and 71.5 percent of contributions were made to these entities. The primary source of revenue for these organizations was program service revenue (73.1 percent), with charitable contributions accounting for a much smaller amount (12.9 percent).

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      (a) IRS in General

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      1 21 IRS 2019 Data Book (issued on June 29, 2020). This reference to tax‐exempt organizations is to entities that are exempt from federal income tax pursuant to IRC § 501(a) by reason of description in IRC § 501(c) (see Parts Three and Four). The concept of recognition of tax exemption is the subject of § 3.2.

      2 22 These data are from Giving USA 2020, published by the Giving USA Foundation, and researched and written by the Center on Philanthropy at Indiana University.

      3 66.1 See Part Three.

      4 66.2 The data in this paragraph are derived from Congressional Research Service, “Tax Issues Relating to Charitable Contributions and Organizations” 3, 13–14 (R45922 (Sept. 19, 2019)).

      5 66.3 See § 28.2(a)(i).

      6 84.1 Taxpayer First Act, 133 Stat. 981 (Pub. L. No. 116‐25, 116th Cong., 1st Sess. (2019)) (for purposes of infra notes 84.2–84.8, Act).

      7 84.2 Act § 1302.

      8 84.3 Id. § 1101.

      9 84.4 Id. § 2101.

      10 84.5 Id. § 2001.

      11 84.6 Id. § 2002.

      12 84.7 Id. § 2003.

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