Social Welfare Organizations 501(c)(4): Permissible activities, obtaining status, and tax implications

Stephanie Robbins | Harmon, Curran, Spielberg & Eisenberg LLP

Stephanie Robbins is an attorney at Harmon, Curran, Spielberg and Eisenberg. She advises the firm’s clients on the complex tax laws and processes that regulate their day-to day activities, as well as state law, corporate law, and governance issues. Ms. Robbins specializes in advising charities on setting up and operating complex corporate structures and the requirements under federal and state law regarding lobbying and political activities. Ms. Robbins also advises on domestic and international grantmaking, fiscal sponsorship, and other issues unique to charities. She particularly enjoys representing the firm’s clients in tax controversies before the Internal Revenue Service.

Prior to joining Harmon Curran in 2021, Ms. Robbins spent ten years with the IRS. She began in 2011 as a Presidential Management Fellow with an appointment as a tax law specialist in the business unit devoted to tax-exempt and government entities (TE/GE). In this position, Ms. Robbins reviewed complex applications for recognition for various types of charities, including public charities, private foundations, title-holding companies, social welfare organizations, and business leagues. She also authored rulings in response to taxpayer requests, responded to taxpayer correspondence, and served as a subject matter expert for specific types of charities.

In 2014, Ms. Robbins joined the IRS Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes (EEE)) as an Honors Attorney. As an attorney advisor, Ms. Robbins authored significant guidance and letter rulings affecting different types of charities, including hospitals. Ms. Robbins also regularly supported IRS field attorneys with examinations and the Department of Justice with litigation. Ms. Robbins served as a subject matter expert for issues such as unrelated business income earned by charities and the political and lobbying activities of charities.

Before joining the IRS, Ms. Robbins earned Juris Doctor from Temple University in 2011. Ms. Robbins then earned a Master of Laws in Taxation from Georgetown University Law Center in 2013.

Gregory A. Nielsen | Nielsen Training & Consulting, LLC

Gregory Nielsen is a sought-after speaker and Consultant committed to helping leaders and organizations translate vision into reality. He is an accomplished nonprofit CEO, having previously led the Center for Nonprofit Excellence. His leadership was recognized locally and nationally and honored with awards from the Better Business Bureau for Ethics and the Louisville Urban League for championing diversity. Gregory is a military veteran, having previously served as an officer and attorney in the United States Army. He holds a Bachelor of Arts Degree in Government and International Relations from the University of Notre Dame and a Juris Doctorate from Notre Dame Law School.

Session I – Understanding the Purposes and Tax Implications of Social Welfare Organizations | 2:00 pm – 3:00 pm

• Definition and purpose of social welfare organizations
• Differences between social welfare organizations and charitable organizations 501(c)(3)
• Permissible activities for social welfare organizations
• Tax implications of operating a social welfare organization

Break | 3:00 pm – 3:10 pm

Session II – Governance and Operational Best Practices | 3:10 pm – 4:10 pm

• Board governance and fiduciary duties
• Roles and responsibilities of the board of directors
• Legal duties of board members (duty of care, duty of loyalty)
• Best practices for board governance