(in Billions)
In 2019, tax-exempt nonprofit organizations reported nearly $3.3 trillion in income and roughly $3.1 trillion in expenses, which resulted in $238 billion in net income. They commanded over $8 trillion in assets.
The largest category of nonprofit by far is the 501(c)(3) category of organizations. In 2019, these organizations booked nearly $2.5 trillion in revenues, equal to 75 percent of all nonprofit revenues. Their net income totaled nearly $152 billion, equal to 63 percent of all nonprofit net income. They also manage the majority of nonprofit assets.
The largest member-serving organizations by income include various insurance and retirement entities under sections 501(c)(4) Civic Leagues and Social Welfare Organizations (the largest of which are health insurers), 501(c)(9) Voluntary Employee’s Beneficiary Associations, and 501(c)(11) Teachers Retirement Fund Associations.
Federal and state credit unions, operating under sections 501(c)(1) and 501(c)(14), respectively, together generated $82.4 billion in revenues in 2019 and commanded over $1.5 trillion in assets in 2019, equal to 18 percent of all nonprofit assets.
Let’s first take a deeper look at public-serving nonprofits since they are by far the largest sector.
The universe of public-serving nonprofits is vast and diverse. Indeed, to manage this diversity, 501(c)(3) organizations have been further segmented into 28 codes under the National Taxonomy of Exempt Entities (NTEE), as illustrated in Table 2 below.
However, if we were to generalize the public-serving nonprofit industry by its dominant industries, it could be called the hospital, health insurance, university, and education sector. Of the $2.5 trillion in revenues collected by 501(c)(3) organizations in 2019, 55 percent was generated by nonprofit hospitals and health insurance firms, and another 12 percent was generated by higher education entities such as colleges and universities.
In 2019, there were 325 501(c)(3) nonprofits with more than $1 billion in revenues—nearly all were either hospitals or universities. Among the $1 billion organizations that were not hospitals or universities:
The largest nonprofit in America is Kaiser Permanente. In 2019, Kaiser’s health plan, hospitals, and state health plans generated more than $110 billion in combined tax-exempt revenues and over $5.6 billion in net income. No other nonprofit came close to Kaiser’s revenues. If Kaiser were for-profit, it would be among the Fortune 40 in revenues.
NTEE Code | 501(c)(3) Sector Classification | TOTAL REVENUES (in Billions) | PROGRAM REVENUE (in Billions) | EXPENSES (in Billions) | NET INCOME (in Billions) | TOTAL ASSETS (in Billions) | Percent Progam Service Revenues |
---|---|---|---|---|---|---|---|
A | Arts, Culture & Humanities | $50.6 | $17.4 | $45.4 | $5.2 | $168.4 | 34% |
B | Education | $156.1 | $67.2 | $137.9 | $18.2 | $544.8 | 43% |
BH | Higher Education | $294.4 | $202.0 | $272.2 | $22.2 | $911.2 | 69% |
C | Environment | $12.7 | $2.8 | $11.2 | $1.5 | $38.8 | 22% |
D | Animal Related | $11.5 | $3.4 | $9.9 | $1.6 | $27.2 | 29% |
E | Health - General | $374.7 | $322.5 | $370.6 | $4.0 | $399.8 | 86% |
EH | Hospitals | $996.8 | $926.0 | $940.0 | $56.8 | $1,517.7 | 93% |
F | Mental Health | $40.6 | $26.5 | $39.3 | $1.2 | $34.7 | 65% |
G | Health - Disease Specific (general) | $28.5 | $13.1 | $29.5 | -$1.0 | $43.4 | 46% |
H | Health - Disease Specific (research) | $14.5 | $2.6 | $13.4 | $1.1 | $51.9 | 18% |
I | Crime, Legal Related | $10.6 | $2.5 | $9.8 | $0.8 | $11.7 | 24% |
J | Employment, Job Related | $21.0 | $11.6 | $20.1 | $0.9 | $20.1 | 55% |
K | Food, Agriculture, Nutrition | $17.8 | $1.4 | $17.0 | $0.8 | $10.1 | 8% |
L | Housing, Shelter | $32.0 | $18.6 | $29.6 | $2.3 | $111.3 | 58% |
M | Public Safety, Disaster Preparedness | $3.9 | $1.1 | $3.6 | $0.3 | $8.8 | 29% |
N | Recreation and Sports | $23.6 | $15.2 | $22.0 | $1.6 | $31.8 | 64% |
O | Youth Development | $10.9 | $2.6 | $10.2 | $0.7 | $21.3 | 24% |
P | Human Services, Multipurpose and Other | $163.8 | $92.2 | $158.8 | $5.0 | $231.9 | 56% |
Q | International, Foreign Affairs | $43.8 | $4.8 | $43.3 | $0.5 | $61.6 | 11% |
R | Civil Rights/Advocacy | $4.5 | $0.7 | $4.0 | $0.5 | $5.8 | 16% |
S | Community Improvement | $24.3 | $8.8 | $22.2 | $2.1 | $67.5 | 36% |
T | Philanthropy, Voluntarism | $76.1 | $4.2 | $54.2 | $21.8 | $304.9 | 5% |
U | Science and Technology | $28.5 | $11.2 | $27.3 | $1.2 | $32.8 | 39% |
V | Social Science | $4.8 | $1.2 | $4.1 | $0.6 | $11.5 | 24% |
W | Public, Society Benefit | $13.7 | $6.8 | $13.4 | $0.3 | $39.3 | 49% |
X | Religion Related | $23.1 | $5.3 | $21.7 | $1.5 | $44.7 | 23% |
Y | Mutual/Membership Benefit | $4.5 | $3.3 | $4.7 | -$0.2 | $29.0 | 73% |
Z | Unknown, Unclassified | $2.1 | $1.7 | $2.1 | $0.0 | $2.9 | 82% |
Total 501c3 Organizations = | $2,489.2 | $1,776.7 | $2,337.6 | $151.6 | $4,785.0 | 71% |
The other hospitals with more than $10 billion in revenues included the University of Pennsylvania Medical Center (UPMC) with $14.8 billion in revenues, Partners Health Care System with $13.6 billion, the Cleveland Clinic Foundation with $11.5 billion, and the Mayo Clinic Group with $10.4 billion.
Overall, nonprofit hospitals and health plans generated $1.4 trillion in revenues in 2019 and $61 billion in net income. They held assets of $1.9 trillion. Very little of this income comes from charitable contributions or grants. Urban Institute data shows that charitable contributions comprised 10 percent of hospital revenues and just 3 percent of health plan revenues.
Most hospital revenues are considered “program service income,” which includes insurance payments, patient reimbursements, and payments from Medicare and Medicaid. For health plans, most income is earned from insurance premiums.
Had these profitable health insurance and hospital firms been taxed at the standard corporate tax rate of 21 percent, they could have collectively been liable for nearly $13 billion in taxes in 2019.
In 2019, there were 51 private universities with more than $1 billion in revenues. Ten universities reported more than $5 billion in income, including the University of Pennsylvania, Harvard, New York University, Johns Hopkins, Stanford, University of Southern California, Columbia, Massachusetts Institute of Technology, Yale, and Cornell. As a group, they held $264 billion in assets.
Collectively, private colleges and universities enjoyed net income of $22.2 billion in 2019. Had they been taxed as for-profit businesses they could have been liable for $4.6 billion in taxes.
Despite their tax-exempt status, the majority of university income comes from sources other than charitable donations from alumni. Overall, nearly 70 percent of university income comes from “program service revenue,” which includes tuition, fees, ticket sales from sporting events, patent royalties, rents from dorms, and cafeteria sales—all considered substantively related to their mission and, thus, exempt from taxes.
By contrast, charitable contributions accounted for 19 percent of total revenues for private universities and colleges.
Many universities have separate investment arms categorized as general “education” organizations, putting them in the same category as private primary and secondary schools.
For example, the $2 billion Gothic Corporation invests on behalf of Duke University. It held $7.6 billion in assets in 2019. Similarly, the Harvard Management Private Equity Corporation managed $31 billion in assets, while the Harvard Private Capital Realty Inc. managed $3.5 billion in assets. The University of Virginia Investment Management Corporation held $9.8 billion in assets, while the University of Wisconsin Foundation reported $4.1 billion in assets.
The Urban Institute dataset contains more than 800 university-related endowments, foundations, and fund-raising entities in 2019. These entities raised a total of $26.8 billion that year and had more than $209 billion in assets. They ended the year with $7.5 billion in net income which, had it been taxed at 21 percent, could have generated more than $1.5 billion in tax revenues.
Many nonprofit categories contain an eclectic mix of large business-like organizations alongside small local organizations. For example, the Arts & Culture sector contains hundreds of local arts projects, dance companies, theater groups, and orchestras. It also includes some very large institutions that could very well be considered for-profit organizations. The Harvard Business School Publishing Corporation is a good example.
In 2019, Harvard Business School Publishing (HBS) generated more than $265 million in revenues. According to its 990 tax return, it ended the year with net income of $3.9 million and paid about $1.1 million in taxes on $14 million in advertising income unrelated to its core mission. [24] On paper, it would appear that HBS generated very little in the way of “profits” on its book publishing activities, but that is because it made a $52.9 million transfer to the “President and Fellows of Harvard College” that it booked as an expense, which reduced its true net income. However, if HBS were a for-profit firm, it would be able to deduct any gifts to Harvard or any other nonprofit.
In some respects, this is similar to NYU’s attempt to use the profits from pasta sales to fund university activities. The only difference in Harvard’s case is that both entities are 501(c)(3) organizations.
Other business-like entities under the Arts & Culture umbrella include the Corporation for Public Broadcasting, the Public Broadcasting Service, National Public Radio, and the WGBH network, all nonprofit competitors of for-profit television and radio networks.
Another unique “cultural” entity is Creative Testing Solutions, which generated over $400 million in revenues in 2019, “Providing innovative, customized and exceptional laboratory testing services, in support of our healthcare partners and their life saving missions.” [25] These services seem very commercial in nature.
Science research was one of the earliest activities to be made tax-exempt. But it is unlikely that those early lawmakers could have imagined how big of an industry “science research” and consulting services has become today and how much it lives off of government largess.
The biggest of these organizations is the Battelle Memorial Institute. By all appearances, Battelle is a government contractor. It manages nine national laboratories for the U.S. Department of Energy and Department of Homeland Security. Battelle bills itself as providing “comprehensive scientific solutions to companies and government agencies across multiple markets.” [26] According to Battelle’s 2021 990 tax return, the organization generated $10 billion in revenues, 97 percent of which was from government grants and contracts.
Similar stories can be told about large tax-exempt science and engineering consulting organizations such as the MITRE Corporation, Aerospace Corporation, Fermi Research Alliance LLC, SRI International, Cold Spring Harbor Laboratory, Noblis Inc., SRC Inc., and In-Q-Tel Inc. Each of these organizations provides services for the government and corporations comparable to those provided by for-profit consulting and management firms. They just provide such services as a 501(c)(3) tax-exempt nonprofit.
Many universities have established affiliated research and consulting organizations to provide support and resources for the research activities of the university. The largest of these is the Research Triangle Institute (RTI), which was organized in 1958 by the state universities of North Carolina along with Duke University, which is private. RTI generated more than $967 million in revenues in 2019.
RTI’s online promotional material reads like a commercial research and consulting firm. [27] RTI bills itself as “a leading independent, nonprofit research institute, with the contractual, legal, and business structures to serve any client with projects of all sizes.” It combines “the scientific rigor of a university with the focus of a project management firm . . . to deliver what our clients need—on target and on time.”
RTI’s 990 tax return reports that the organization does have “several for-profit entities subject to corporate income taxation,” and its presence in “certain foreign countries results in income taxation in these countries.” [28] Yet, RTI qualifies as a 501(c)(3) tax-exempt organization under the U.S. tax code.
Because of the growth of business-like income over the past three decades, it is hard to call the 501(c)(3) sector the “charitable” sector anymore. Figure 1 shows how the growth in program service revenues has driven the overall growth in nonprofit revenues over the past 30 years. Generally speaking, program service revenues can include Medicare and Medicaid payments, payments for medical services from insurers and patients, tuition, ticket sales, royalties, insurance premiums, conference registration fees, fees and contracts from government agencies, and unrelated business income.
Since 1988, program service revenues have risen from $548 billion, in today’s dollars, to more than $1.8 trillion in 2019—an increase of 310 percent. [29]
Program revenues comprised 71 percent of nonprofit revenues in 2019, up from 67 percent in 1988. By contrast, charitable contributions comprised just 12 percent of nonprofit revenues in 2019.
As surprising as this may seem, the real story is that charitable contributions have never been the dominant source of income for 501(c)(3) organizations or for tax-exempts generally. As we saw in the Treasury Department’s 1949 study, even for organizations without business-related income, charitable donations were exceeded by dues, membership fees, and other income sources.
IRS data shows that as a share of 501(c)(3) income, contributions fell from 27 percent in 1975 to 18 percent in 1982 and 12 percent in 2019. [30]
While the 1949 Treasury study separated tax-exempt organizations into business and nonbusiness types, a third type of nonprofit has emerged since the Great Society of the 1960s—government-dependent organizations. Such organizations derive most of their income from government grants, contracts, or programs such as Medicaid, Medicare, public housing, and anti-poverty aid.
As we saw with the research and consulting organizations discussed above, many government agencies rely on nonprofit organizations as contractors or subcontractors, managing programs such as public housing, transit systems, social services, and job training.
Figure 1 shows that government grants alone nearly equal charitable contributions in most years, and government grants do not include revenues from government contracts or programs such as Medicare and Medicaid, which are considered program service income.
Many of the organization types we have reviewed so far are business-like in form and function. But looking at the list of 501(c)(3) NTEE categories, a few stand out as containing more benevolent organizations than business-like organizations.
Employment and job-related organizations (category J) range from job training services to local trade unions. Perhaps the most prominent name in this category is Goodwill Industries, with some 180 local chapters. Dress for Success is another national organization with more than 50 chapters providing business attire and training to women seeking jobs. [31]
A sizeable number of organizations in this category are lesser-known community-based vocational training and apprenticeship organizations supported by government grants and private donations. Trade unions operate similar apprentice and training programs for carpenters, masons, electricians, and pipe fitters, for example.
Standing out from such training programs are numerous local union chapters, supported by member dues.
The most benevolent-centered category is K, representing food, agriculture, and nutrition organizations. The Urban Institute dataset includes more than 5,700 food, agriculture, and nutrition organizations with total revenues of nearly $17.8 billion in 2019. Here we find that nearly every organization is a food bank, food pantry, child hunger-related organization, or adult nutrition service such as Meals on Wheels. The largest such organization is the $2.8 billion Feeding America, but most are local in nature such as the $10 million Food Bank of East Alabama and the $30,000 Westlake Meals on Wheels.
Overall, contributions and grants comprised 90 percent of the revenues for food and nutrition organizations in 2019, which clearly sets these benevolent organizations apart from most other nonprofits.
The housing and shelter organizations comprising category L include a mix of benevolent organizations, government contractors, and business-like entities. Many of the larger organizations in this category are public housing providers or management contractors. The largest such organization is Navigate Affordable Housing Partners in Birmingham, Alabama, which received 99.7 percent of its $605 million in 2019 income from U.S. Department of Housing and Urban Development grants and contracts. [32]
Vetter Senior Living in Elkhorn, Nebraska , is also representative of the more business-like organizations in this category. Started in 1975 by Jack and Eldora Vetter, this chain of senior living facilities received more than half ($134 million) of its $222.5 million in revenues from Medicaid and Medicare in 2019. [33] Most of the remaining income came from “patient service revenue” and “management revenues.” [34] On the surface, it is difficult to distinguish between the services that Vetter provides as a “nonprofit” and those provided by for-profit senior living companies.
Habitat for Humanity is the largest of the more traditional volunteer-based service organizations found in this category. The vast majority of its $288 million in revenues in 2019 came from grants, contributions, and in-kind gifts. [35]
Multipurpose is the operative term for human service organizations in category P. The largest organization in this category is the American Red Cross with more than $2.8 billion in income in 2019. The AARP Foundation is also listed as a human service organization and illustrates how some large nonprofits use related tax-exempt entities to expand their operations. Its 990 for 2019 shows that it is affiliated with other AARP entities, including the main AARP entity, which is a 501(c)(4) nonprofit. [36] The main AARP entity booked some $1.7 billion in revenues in 2019, including more than $977 million in tax-free royalty income. [37]
The Urban Institute datasets include more than 600 separate filings for local YMCA or WYCA chapters, which have combined income of $6.1 billion and assets of $12 billion. By contrast, the largest for-profit fitness company by income is LA Fitness, which also has 600 locations but only $2 billion in revenues.
But the category also includes an interesting variety of smaller organizations, such as dog rescues, adult day care centers, children’s day care centers, hospice care, community centers, thrift stores, pregnancy centers, diaper banks, and yoga studios.
Almost by definition, organizations other than 501(c)(3) entities have a business orientation in some manner, even if they were intended to be member-serving. These include credit unions, rural utilities and coops, insurance companies, pension funds, business and sports leagues, cemeteries, real estate holding companies, farmer coops, fraternal organizations, social and recreation clubs, and veterans organizations.
Let’s explore a few of these categories.
501(c)(4) organizations are a good example of how tax-exempt definitions can be expanded to include big businesses. While tax laws require that such organizations be “operated exclusively to promote social welfare,” that concept seems to have been interpreted broadly. [38]
Washington insiders may associate 501(c)(4) organizations with activist and public policy organizations like the Sierra Club and the American Civil Liberties Union, but such organizations are in the minority. Social welfare organizations seem to be split between a few hundred large health-related firms and thousands of smaller 501(c)(4) organizations such as Rotary clubs, Kiwanis, Lions clubs, Optimist clubs, American Legion, Links chapters, homeowners associations, and volunteer fire departments.
The largest 501(c)(4) entities, those with more than $100 million in revenues, are predominantly health-related firms such as dental plans, HMOs, and health-care networks. Delta Dental Plans, with roughly 30 state entities, is the largest of these organizations. In 2019, it had combined revenues of more than $15 billion and net income of $339 million.
Perhaps the most unusual of these large “social welfare” organizations is the Prairie Meadows Racetrack & Casino Inc. in Altoona, Iowa . Originally launched as a commercial venture, which went bankrupt, it was converted into a nonprofit in 1994 and is reportedly one of only two nonprofit casinos in the U.S. With more than $2.3 billion in 2019 revenues, Prairie Meadows says it is “dedicated to lessening the burden of government by raising funds for charitable organizations and community improvement projects.” [39]
Prairie Meadows’ mission statement is an interesting justification for the tax-exempt status of what was a failed commercial venture. It harkens back to the 1909 Senate quandary whether the for-profit Methodist Book Concern should pay the corporate income tax A corporate income tax (CIT) is levied by federal and state governments on business profits. Many companies are not subject to the CIT because they are taxed as pass-through businesses , with income reportable under the individual income tax . because it gave away its profits to charitable causes. And tying a casino’s charitable status to “lessening the burden of government” is a questionable principle that could open the door to no end of dubious “commercial” but tax-exempt enterprises, such as a “nonprofit” marijuana dispensary.
The 501(c)(6) “business league” category could be called the tax-exempt home of K Street lobbyists, golf and tennis companies, professional guilds, and tourism boards. The U.S. Chamber of Commerce is said to have led the effort in 1913 to exempt business membership organizations and civic leagues from tax during the debate over the Revenue Act of 1913. Indeed, some of the biggest business groups in Washington, D.C., are organized as 501(c)(6) entities, including the U.S. Chamber of Commerce, American Petroleum Institute, American Hospital Association, American Bureau of Shipping, American Chemistry Council, National Milk Producers Federation, and National Association of Broadcasters.
Many professional sports organizations are also organized as “business leagues.” While the NFL, MLB, and NBA renounced their tax-exempt status years ago, a number of prominent professional sports leagues still maintain their tax-exempt status. These include the PGA, United States Tennis Association, ATP Tour, Ladies Professional Golf Association, WTA Tour Inc., United States Polo Association, the Breeders Cup Limited, National Hot Rod Association, and Professional Golfers Association of America.
This is also a common organizational form for professional organizations, such as the American Bar Association, American Medical Association, National Association of Realtors, Academy of Motion Picture Arts and Sciences, and Motion Picture Association.
Advertising and promotional organizations are frequently organized as 501(c)(6) organizations. Notable promotional organizations include the Houston Super Bowl Host Committee, Avocados from Mexico , United States Meat Export Federation, Greater Miami Convention and Visitors Bureau, Atlanta Convention & Visitors Bureau, and Dairy Promotion Inc.
The social and recreation clubs represented in the 501(c)(7) classification may consist of some of the most exclusive golf, athletic, and social clubs in the United States. Social and recreational clubs were exempted from tax in the 1916 Tax Act. Many of the largest cities have exclusive social and athletic clubs, including the New York Athletic Club, the Detroit Athletic Club, the Atlanta Athletic Club, the Yale Club of New York City, the Harvard Club of New York City, and the Bohemian Club near San Francisco. Indeed, the Tax Foundation was organized at a meeting of business leaders in 1937 at the University Club in New York City.
Golf courses dominate the 501(c)(7) category of nonprofit organizations, including some of the most iconic and exclusive golf clubs in America, such as the Congressional Country Club, Baltusrol Golf Club, Winged Foot Golf Club, Oakmont Country Club, and Sawgrass Country Club. By contrast, Augusta National Golf Club, which hosts the Masters tournament, is a for-profit corporate entity.
The richest of all the clubs in 2019 was the Desert Mountain Club in Scottsdale, Arizona , which reported $68 million in revenues. Membership to this exclusive golf and lifestyle community is by “invitation only.” [40] The Club’s real estate listings include homes ranging from $1.5 million to nearly $13 million.
There are certainly smaller, less famous clubs in this category, including a Giant Schnauzer club, local boating clubs, swim and tennis clubs, kennel clubs, singing clubs, model train clubs, a Slovak Citizens club, and various cotillion clubs.
Fraternal beneficiary societies organized under 501(c)(8) of the tax code are now largely insurance companies. Fraternal beneficiary societies were a prevalent part of America’s self-help culture when the first income taxes were being drafted, first in 1894 and then in 1909. Yet, as B.H. Meyer explained in an academic study in 1900, there was always a tension between their social function and their beneficiary function.
Fraternal beneficiary societies, as the name suggests, are dual in their nature. Because they are both fraternal and beneficiary, these societies are really composed of two organizations each: a fraternity and an insurance company . . . In other words, a typical fraternal society rests upon three things: first, voluntary organization on a basis of equality; second, some ritualistic system; and third, a system of benefits. These three are united in different proportions in different societies, and in not a few of them a struggle for predominance is taking place between the first and third. This is the battle between “fraternalism and commercialism.” [41]
More than 100 years later, the commercial side of these organizations has won out. For example, WoodmenLife—which was founded in 1890—offers various types of life insurance and retirement products. [42] Modern Woodmen (unrelated to WoodmenLife) offers an even broader portfolio of products beyond life insurance, such as retirement planning, estate planning, and employee benefits. [43] The Knights of Columbus does have a well-known service side, but also offers its members retirement annuities, mutual funds, donor advised funds, and various life insurance policies. [44]
The products and services offered by these nonprofit organizations are in direct competition with similar products offered by for-profit financial service firms.
Tax-exempt public electric, water, and utility companies are a legacy of Depression-era efforts to promote rural self-help. Today’s 501(c)(12) tax-exempt utilities were formed as “cooperatives” during the early 1900s to bring electricity and water services to rural areas at a time when the larger urban utilities didn’t find it profitable to reach those markets. In 1934, Congress created the Rural Electrification Administration—now the Rural Utilities Service (RUS)—within the U.S. Department of Agriculture to promote the growth of rural coops and provide them low-cost financing.
Some 90 years later, rural coops are still dependent upon their tax-exempt status and subsidized loans. Notably, many of the “rural” communities these coops were created to serve are now prosperous suburbs of cities such as Washington, D.C., and Atlanta, Georgia , not to mention tony resort communities such as Sanibel and Marco Island in Florida .
This ecosystem of tax-exempt utilities is supported by two larger tax-exempt organizations. The industry’s lobbying arm is the National Rural Electric Cooperative Association, a 501(c)(6) membership organization. [45] The industry’s lending arm—independent of the federal RUS—is the $1.38 billion National Rural Utilities Cooperative Finance Corporation (CFC). CFC is a 501(c)(4) entity and bills itself as “Bridging the financial needs of the rural electric cooperative network with global capital markets.” [46] It has more than $35 billion in assets.
Congress enacted UBIT in 1950 with the aim of leveling the playing field between tax-exempt organizations and for-profit firms. But as Jeffrey Scott Tenenbaum wrote in his primer on UBIT for the American Bar Association, “instead of prohibiting tax-exempt entities from engaging in any business activities at all . . . Congress chose to specifically permit a certain degree of business activity by tax-exempt organizations, but tax that activity like any other for-profit business.” [47]
Thus, writes Tenenbaum, “such business activities are permissible, so long as the activities are not a ‘substantial part of [the nonprofit’s] activities.’ The tax applies to virtually all tax-exempt entities.”
A frequent example of the difference between taxable and non-taxable sales activities is a museum gift shop that sells greeting cards bearing reproductions of paintings in the museum’s collection as well as local maps and souvenirs. UBIT rules would require the museum to pay tax on the income generated by the souvenirs because those items are not related to the museum’s mission. But it would not pay UBIT on income generated by the greeting cards with an image of a Monet because those sales are related to the museum’s mission of advancing art appreciation. [48]
The Harvard Business School magazine is another example. HBS does not pay tax on the income generated by its business publications or magazine subscriptions because they are determined to be a key element of the organization’s mission. However, HBS does pay tax on the income generated by the advertising in the magazine because those promote private and commercial interests separate from HBS’s mission.
There are, however, numerous exemptions to UBIT that give organizations wide latitude to earn business-like income. This includes income from corporate sponsorships, royalties, TV broadcast rights, certain rents, interest, dividends, and convention fees to name a few.
As a result of UBIT’s narrow scope and numerous exemptions, the tax raises very few revenue. IRS data on UBIT revenues from 1990 to 2017 shows that, on average, 17 percent of nonprofit charitable organizations reported unrelated business income and roughly half of those organizations were liable for UBIT. After adjusting for inflation Inflation is when the general price of goods and services increases across the economy, reducing the purchasing power of a currency and the value of certain assets. The same paycheck covers less goods, services, and bills. It is sometimes referred to as a “ hidden tax ,” as it leaves taxpayers less well-off due to higher costs and “bracket creep,” while increasing the government’s spending power. , UBIT raised an average of $586 million per year from 1990 to 2017, less than 0.5 percent of the billions in net income charitable nonprofits generated each year. [49]
So rather than level the playing field, UBIT has had little to no effect on preventing nonprofits from engaging in business-like activities nor competing directly with for-profit firms.
After more than 100 years of nonprofit expansion into the business economy, it is time that lawmakers developed some simple and uniform rules that accomplish two things: 1) distinguish between benevolent organizations and business-like entities, and 2) expressly level the playing field between the business activities of nonprofit and for-profit entities.
Three changes would remove the tax advantage that business-like nonprofits have over for-profit firms while protecting the charitable income of benevolent organizations.
Step 1: The first step is to raise the threshold for the percentage of charitable contributions a 501(c)(3) organization must receive to be considered a “publicly supported” charity. Currently, an organization needs to show that it receives at least 30 percent of its revenues from “public” sources to be considered a public charity eligible to accept tax-deductible donations. Public sources is a broad concept that includes contributions from the public, government grants, grants from charitable foundations, net income from unrelated business activities, membership fees, and gross investment income. [50]
Since our goal is to narrow the definition of a “publicly supported” charity to focus on benevolent organizations, the income threshold should be increased to 80 percent and limited to donations from private individuals and grants from charitable foundations. Income from government contracts, government grants for services, membership fees, investment income, and business income should not be included as these sources are more business-like than charitable in nature.
Such a rule would protect the “public charity” status of a women’s shelter that hosts an annual charity ball but would likely deny that status for a nonprofit group such as the Battelle Memorial Institute that receives most of its income from contracts or grants for service from the departments of Energy or Defense, for example.
Step 2: The second step would be to eliminate UBIT and apply the 21 percent corporate income tax to the net program service income of all nonprofit organizations. The calculation of net program service income would differ between 501(c)(3) organizations and other nonprofits because of the need to separate charitable income from program service revenues.
As was discussed earlier, most 501(c)(3) organizations generate income from charitable donations and program service revenue. Program service revenues are the kind of income that a for-profit firm would normally pay tax on, including tuition, fees, Medicare and Medicaid payments, insurance reimbursements, rents, contract income, royalties, and broadcast rights. Under this proposed rule, nonprofits would subtract their program-related expenses from their program service revenues and pay income tax on the remainder.
In the table below, we estimate that 501(c)(3) organizations had $92 billion in net program service income in 2019. Had this net income, or profits, been taxed at the 21 percent corporate tax rate, it could have raised $19 billion in new tax revenues. This estimate does not account for any behavioral effects, nor have we accounted for an adjustment to corporate accounting standards such as bonus expensing.
Calculating taxable income Taxable income is the amount of income subject to tax , after deductions and exemptions . For both individuals and corporations, taxable income differs from—and is less than—gross income. is much simpler for all other exempt organizations since they don’t have to account for charitable contributions. All of their income is assumed to be program service income. These organizations would simply pay the corporate income tax rate on their income net of expenses like any private business.
In 2019, these organizations had $87 billion in net income, or profits. Had these profits been taxed at the 21 percent corporate tax rate, it could have raised $18 billion in revenues.
Lastly, federal credit unions generated $7 billion in net income in 2019 and would have been liable for $2 billion in taxes had they been taxed at 21 percent.
Combined, taxing the net program income of all nonprofits could have raised $39 billion in new revenues in 2019.
Tax-Exempt Sector | Total Revenues | Program Service Revenues | Total Expenses | Total Net Income | Estimated Program Service Expenses | Estimated Net Program Service Income | Tax | Estimated Tax Revenues |
---|---|---|---|---|---|---|---|---|
2019 501(c)(3) | $2,489 | $1,777 | $2,338 | $152 | $1,685 | $92 | 0.21 | |
2019 All other 501(c) | $840 | $754 | $87 | $87 | 0.21 | |||
501(c)(1) Federal Credit Unions | $43 | $36 | $7 | $7 | 0.21 | |||
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Step 3: The final step would be to decide how to tax the investment income—dividends, interest, and capital gains—of tax-exempt organizations. Table 3 includes investment income in the total net “profits” of tax-exempt organizations and, thus, assumes they are taxed at 21 percent. Currently, most nonprofits pay no tax on their investment income under the theory that such income supports the mission of the organization. However, private foundations are required to pay a 1.39 percent excise tax on their investment income. Large university endowments are also required to pay a 1.4 percent excise tax if the endowment assets exceed $500,000 per student.
The rate at which nonprofit investment income is taxed is not a trivial matter. In 2019, the Urban Institute dataset shows that 501(c)(3) organizations reported $51.8 billion in investment income. All other 501(c) organizations reported $19.4 billion in investment income, which brings the total of nonprofit investment income to $71.2 billion. Taxing this income at roughly 1.4 percent rather than 21 percent would yield much less revenue.
The tax exemption for investment income has allowed some large nonprofits to become tax-exempt hedge funds. Tax neutrality demands that all taxpayers pay the same rate on their investment income. Thus, it would make sense to tax the investment income of nonprofits at the 21 percent corporate rate and remove any incentive for arbitrage or income shifting.
Washington faces a brewing fiscal crisis that will force lawmakers to look for additional tax revenues, either to address mounting deficits or to offset the extension of key portions of the 2017 Tax Cuts and Jobs Act—perhaps even both. The fairest and least economically harmful way to raise new revenues is to expand the federal tax base to include business-like income earned by tax-exempt nonprofit organizations.
The rules governing the tax-exempt sector are long overdue for reform. The $3.3 trillion nonprofit economy is dominated by large, business-like organizations that overshadow the truly benevolent organizations the tax exemption should be reserved for.
A reasonable rewriting of the tax-exempt rules should include narrowing the definition of “public charity,” repealing the toothless UBIT, and subjecting all non-charitable income to taxation. Doing so would protect the charitable income of benevolent organizations while leveling the playing field between nonprofits and for-profit entities. Most importantly, tighter rules would also give a principled foundation to the nonprofit sector that has been missing for the past 120 years.
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[1] Author calculations.
[2] Internal Revenue Service, “Exempt Organizations Business Master File Extract (EO BMF),” https://www.irs.gov/charities-non-profits/exempt-organizations-business-master-file-extract-eo-bmf
[3] Author calculations, See Table 1.
[4] Congress of the United States, Joint Committee on Taxation, Historical Development and Present Law of the Federal Tax Exemption for Charities and Other Tax-Exempt Organizations , Apr. 19, 2005, https://www.jct.gov/publications/2005/jcx-29-05/ .
[5] Giving USA, “Giving USA Limited Data Tableau Visualization, 2022 Giving Overview,” https://givingusa.org/giving-usa-limited-data-tableau-visualization/ .
[6] B.H. Meyer, “Fraternal Beneficiary Societies in the United States,” American Journal of Sociology 6:5 (March 1901): 647, https://www.jstor.org/stable/2762005 .
[7] Scott Hodge, “After 90 Years, It Is Time to Wean Credit Unions off Taxpayer Subsidies,” Tax Foundation, Jan. 30, 2024, https://taxfoundation.org/research/all/federal/credit-union-tax-treatment/
[8] Tariff of 1894 (Wilson-Gorman Tariff), Aug. 27, 1894, https://fraser.stlouisfed.org/title/5901 . (The income tax is defined on p. 553 and the tax-exempt language begins on p. 556.)
[9] American Association of Public Accountants, The Corporation Tax Law of 1909, https://egrove.olemiss.edu/cgi/viewcontent.cgi?article=1955&context=aicpa_guides .
[10] 44 Cong. Rec. 4151 (1909).
[12] Ibid., p. 4155.
[13] Ibid., p. 4156.
[14] H.R. 3321, 63 rd Cong. (1913), p. 172, https://fraser.stlouisfed.org/files/docs/historical/congressional/underwood-tariff-1913.pdf .
[15] E. Gordon Keith, “New Data on Tax-Exempt Organizations,” Proceedings of the Annual Conference on Taxation under the Auspices of the National Tax Association 38 (1945): 257-269, www.jstor.org/stable/23404793 .
[16] Individual Income Tax An individual income tax (or personal income tax) is levied on the wages, salaries, investments, or other forms of income an individual or household earns. The U.S. imposes a progressive income tax where rates increase with income. The Federal Income Tax was established in 1913 with the ratification of the 16th Amendment . Though barely 100 years old, individual income taxes are the largest source of tax revenue in the U.S. Return for Calendar Year 1917, Form 1040 Instructions, https://www.irs.gov/pub/irs-prior/f1040--1917.pdf .
[17] Mark B. Edwards, “It All Started With Macaroni: A Trip Through the Shadowy World of UBIT,” prepared for the 2005 Legal Forum, September 2005, https://www.inumc.org/wp-content/uploads/2024/01/unrelatedbusinessincome-1.pdf .
[18] Joint Committee on Taxation (2005), 100.
[19] United States Treasury Department, Bureau of Internal Revenue, “Supplement to Statistics of Income for 1946, Part 2,” October 1949, https://www.irs.gov/pub/irs-soi/46eosupsec2.pdf .
[20] Hodge, “After 90 Years, It Is Time to Wean Credit Unions off Taxpayer Subsidies.”
[21] Internal Revenue Code of 1954, https://www.govinfo.gov/content/pkg/STATUTE-68/pdf/STATUTE-68A-Pg1.pdf .
[22] U.S. Department of Commerce Bureau of the Census, Historical Statistics of the United States, Colonial Times to 1970, Part 1 , (Washington, DC, 1975), 224. Note: In 1909, U.S. GDP was $33.4 billion in current dollars.
[23] “NCCS Core Series Overview,” National Center for Charitable Statistics, https://nccs.urban.org/nccs/datasets/core/ .
[24] IRS, Form 990, Return of Organization Exempt from Income Tax, 2018 , Harvard Business School Publishing Corporation, https://apps.irs.gov/pub/epostcard/cor/043177990_201906_990_2021012817670018.pdf .
[25] Creative Testing Solutions, https://www.mycts.org/ .
[26] Battelle Memorial Institute, https://www.battelle.org/about-us .
[27] RTI International, https://www.rti.org/about-us .
[28] IRS, Form 990, Return of Organization Exempt from Income Tax, 2018 , Research Triangle Institute, https://apps.irs.gov/pub/epostcard/cor/560686338_201909_990_2020101517377917.pdf .
[29] Scott Hodge, “Nonprofits are Financially Healthy and Doing Big Business,” Tax Foundation, Oct. 6, 2023. https://taxfoundation.org/blog/501c3-nonprofit-revenue/ .
[31] Dress for Success, https://www.dressforsuccessqc.org/ .
[32] IRS, Form 990, Return of Organization Exempt from Income Tax, 2019, Navigate Affordable Housing Partners Inc., https://apps.irs.gov/pub/epostcard/cor/630985617_201912_990_2020110517414338.pdf .
[33] Vetter Senior Living, https://www.vetterseniorliving.com/we-believe/history/ .
[34] IRS, Form 990, Return of Organization Exempt from Income Tax, 2018, Vetter Senior Living, https://apps.irs.gov/pub/epostcard/cor/471108168_201906_990_2021012817669748.pdf .
[35] IRS, Form 990, Return of Organization Exempt from Income Tax, 2018 , Habitat for Humanity International Inc., https://apps.irs.gov/pub/epostcard/cor/911914868_201906_990_2020020617119545.pdf .
[36] IRS, Form 990, Return of Organization Exempt from Income Tax 2019, AARP Foundation, 2018 https://apps.irs.gov/pub/epostcard/cor/520794300_201912_990_2021022617763807.pdf .
[37] IRS, Form 990, Return of Organization Exempt from Income Tax, 2019, AARP, https://apps.irs.gov/pub/epostcard/cor/951985500_201912_990O_2022042920018144.pdf .
[38] Internal Revenue Service, “Social welfare organizations,” https://www.irs.gov/charities-non-profits/other-non-profits/social-welfare-organizations .
[39] Prairie Meadows, https://www.prairiemeadows.com/about-us/our-company .
[40] Desert Mountain Club Inc., https://www.desertmountain.com/membership-information/ .
[41] B.H. Meyer, “Fraternal Beneficiary Societies in the United States,” American Journal of Sociology 6:5 (March 1901): 646-661, https://www.jstor.org/stable/2762005 .
[42] Woodmen Life, https://www.woodmenlife.org/extras/ .
[43] Modern Woodmen, https://www.modernwoodmen.org/financial-planning/protection/ .
[44] Knights of Columbus, https://www.kofc.org/en/what-we-do/insurance/index.html .
[45] Cooperative Services Corporation, https://www.cooperative.com/cfc/pages/ncsc.aspx .
[46] National Rural Utilities Cooperative Finance Corporation, https://www.nrucfc.coop/content/nrucfc/en/about-cfc.html .
[47] Jeffrey Scott Tenenbaum, “Unrelated Business Income Tax (UBIT): A Comprehensive Overview for Nonprofits,” Business Law Today, November 2021, https://americanbar.org/groups/business_law/resources/business-law-today/2021-november/unrelated-business-income-tax/ .
[48] Department of the Treasury, Internal Revenue Service, Publication 598: Tax on Unrelated Business Income of Exempt Organizations , Mar. 22, 2021, https://www.irs.gov/pub/irs-pdf/p598.pdf .
[49] Internal Revenue Service, Statistics of Income, Table 16: Nonprofit Charitable Organization and Domestic Private Foundation Information Returns, and Exempt Organization Business Income Tax Returns: Selected Financial Data, Expanded , https://www.irs.gov/statistics/soi-tax-stats-historical-table-16 .
[50] U.S. Department of Treasury, Internal Revenue Service, Publication 557, Tax-Exempt Status for Your Organization , revised January 2014, https://www.irs.gov/pub/irs-pdf/p557.pdf .
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Scope of research refers to the range of topics, areas, and subjects that a research project intends to cover. It is the extent and limitations of the study, defining what is included and excluded in the research. The scope of a research project depends on various factors, such as the research questions, objectives, methodology, and available ...
The scope of a research project is one of the more important yet sometimes understated aspects of a study. The scope of the study explains what the researchers are examining and what environment they are studying. This article explains the general purpose of the research scope, how it informs the broader study at hand, and how it can be ...
Learn what the scope of the study means, why it is important, and how to write one with an example. The scope of the study defines the parameters and limitations of your research project before data collection begins.
What is scope and delimitation in research. The scope of a research paper explains the context and framework for the study, outlines the extent, variables, or dimensions that will be investigated, and provides details of the parameters within which the study is conducted.Delimitations in research, on the other hand, refer to the limitations imposed on the study.
Learn how to define the scope and delimitations of your research study, and why they are important for your research design and writing. See examples of scope and delimitations from published studies and how to write them in your abstract, introduction, methods, and discussion sections.
Scope of research is the part of your project that defines what will and will not be covered. Learn how to determine scope of research based on budget, timeline, population, sample, methodology, and variables.
Learn how to define the scope and delimitations of your research study, and how to write them clearly and concisely. Find out the difference between delimitations and limitations, and see examples of both.
In simpler words, scope is the breadth of your study, while delimitation is the depth of your study. Scope and delimitation are both essential components of a research project, and they are often confused with one another. The scope defines the parameters of the study, while delimitation sets the boundaries within those parameters.
The scope of your project sets clear parameters for your research.. A scope statement will give basic information about the depth and breadth of the project. It tells your reader exactly what you want to find out, how you will conduct your study, the reports and deliverables that will be part of the outcome of the study, and the responsibilities of the researchers involved in the study.
Learn how to write research objectives that describe what your project intends to achieve and explain why you are pursuing it. Find out how to formulate SMART objectives and how they relate to your research aim and scope.
The scope of a study explains the extent to which the research area will be explored in the work and specifies the parameters within the study will be operating. Basically, this means that you will have to define what the study is going to cover and what it is focusing on. Similarly, you also have to define what the study is not going to cover.
In order to write the scope of the study that you plan to perform, you must be clear on the research parameters that you will and won't consider. These parameters usually consist of the sample size, the duration, inclusion and exclusion criteria, the methodology and any geographical or monetary constraints. Each of these parameters will have ...
Answer: Scope and delimitations are two elements of a research paper or thesis. The scope of a study explains the extent to which the research area will be explored in the work and specifies the parameters within which the study will be operating. For example, let's say a researcher wants to study the impact of mobile phones on behavior ...
To write your scope of the study, you need to restate the research problem and objectives of your study. You should state the period in which your study focuses on. The research methods utilized in your study should also be stated. This incorporates data such as sample size, geographical location, variables, and the method of analysis.
The scope of the study explains the extent to which your research area will be explored, and the parameters the study will operate. It gives the reader and the writer an insight into what the ...
The scope of the study explains the extent to which your research area will be explored, and the parameters the study will operate. It gives the reader and the writer an insight into what the study is aimed at and what should be anticipated. This implies that the scope of the study should define the purpose of your study, the sample size and ...
Here are the steps to write the background of the study in a research paper: Identify the research problem: Start by identifying the research problem that your study aims to address. This can be a particular issue, a gap in the literature, or a need for further investigation. Conduct a literature review: Conduct a thorough literature review to ...
Significance of the study in research refers to the potential importance, relevance, or impact of the research findings. It outlines how the research contributes to the existing body of knowledge, what gaps it fills, or what new understanding it brings to a particular field of study. ... Scope and limitations: This outlines the boundaries and ...
Answer: The scope of a study explains the extent to which the research area will be explored in your work, and it specifies the parameters within which the study will be operating. In other words, you will have to define what the study will cover and what it focuses on. Similarly, you also have to explain what the study will not cover.
Scope and delimitations are two of the most important factors to consider when writing a research paper. They help to identify what is included in the study and what is not. Without them, it would be difficult to know what information is relevant and what is not. By definition, the scope of the study is the limits within which the research will ...
The scope of a study, as you may know, establishes the extent to which you will study the topic in question. It's done, quite simply, to keep the study practical. If the scope is too broad, the study may go on a long time. If it's too narrow, it may not yield sufficient data. For examples of the scope, you may refer to the following queries ...
Research objectives are specific goals or purposes that guide a study or investigation. They are clearly defined statements that outline what the researcher aims to achieve through their research.These objectives help to focus the study, provide direction, and establish the scope of the research design.They typically include the main questions or problems the research seeks to address and are ...
For example, in their 2021 Cell Reports study on macrophage polarization mechanisms, dermatologist Alexander Marneros and colleagues wrote the following. 1. A limitation of studying macrophage polarization in vitro is that this approach only partially captures the tissue microenvironment context in which many different factors affect macrophage polarization.
The Scope of This Study Is Limited to 501(c) Organizations. ... As we saw with the research and consulting organizations discussed above, many government agencies rely on nonprofit organizations as contractors or subcontractors, managing programs such as public housing, transit systems, social services, and job training. ...
A research question is a qualitative or quantitative enquiry that a study sets out to answer. These two concepts can be viewed together in many ways, one of which is to think of research questions as a means to specify the scope. Take cyberbullying as an example: this topic is very broad in scope, and spills over areas of psychology, education ...
1 Answer to this question. Answer: The scope of a study explains the extent to which the research area will be explored in the study and specifies the parameters within which the study will be operating. Thus, the scope of a study will define the purpose of the study, the population size and characteristics, geographical location, the time ...
Scope refers to the extent of the topic you will be covering in your study. This is done to keep the study feasible and practical in terms of cost, efforts, and time. A related term is delimitations, which refers to the restrictions placed on the study by the researcher. Scope and delimitations are written in the Methods section.