IRS Ruling Takes Aim at Impact Investing

What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service released Private Letter Ruling 202041009 (the “Ruling”), concluding that a nonprofit organization (the “Nonprofit”) that manages impact investment funds at below market fees is not a charitable organization. The ruling states that the Nonprofit was formed “exclusively for...
By: Polsinelli

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