Formation of entities:

  • Formation of many 501(c)(3), 501(c)(4) and other non-profit entities, including analyzing the organizational test, primary purpose test and operational test; and
  • Structuring the entity to qualify for one of the 501(c)(3) purposes, including : relief of poor; relief of distressed; promotion of health; lessening burdens of government; advancement of education; advancement of science; advancement of religion; promotion of social welfare; promotion of arts; environmental protection; promotion of sports; and promotion of local economic development.

Analyzing concerns in creating entities:

  • Education versus propaganda;
  • Religion and scope of definition;
  • Church ancillary functions and qualifying for religion; and
  • Refuting IRS arguments that the nonprofit operation is similar to a commercial enterprise operated for profit;