- Client: Charitable Organization
- Date: June 2007
- Location: Illinois
Schiff Hardin's Tax-Exempt Organizations team assisted a client in obtaining IRS recognition of its tax-exempt status. In doing so, the team overcame the initial objections of a very skeptical Internal Revenue Service examiner who raised issues involving private inurement, private benefit, and possible impermissible political activities.
The IRS demanded a vast amount of explanation and documentation, some of which was not easy to provide to a satisfactory degree. Thus, the Schiff Hardin team crafted an overall response designed to show that, despite appearances, no one benefits from the organization other than the class that it was created to serve, and that, instead of benefiting in any way, the members of the organization have had to make sacrifices to make the endeavor successful. It was this sophisticated strategy, as much as the answers to the IRS's specific questions, that led to a favorable outcome for our client.