NAAG provides a growing library of on-demand resources*, including courses, archived podcasts, and more, designed to deliver practical, high-quality training for the attorney general community.

Our on-demand courses include recordings of prior programs as well as purpose-built learning experiences covering a wide range of topics relevant to attorney general community and beyond. On-demand courses are available to both members and non-members, with certain offerings eligible for continuing legal education (CLE)** credit depending on the course and jurisdiction.

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Reviewing Nonprofit/For-Profit Structures
Audience
Members Only

Topic(s)
Charities

CLE Status
Eligible

Original Production
12/16/2025

Duration
1 hr 0 mins

Cost
Members
Included in Membership

Course Description

This course provides an in-depth examination of the legal frameworks governing nonprofit and for-profit structures, focusing on the interplay between state charity law and federal tax law. Participants will explore the essential requirements for nonprofit organizations when engaging in transactions with for-profit entities, including the implications of joint ventures and the formation of for-profit subsidiaries. The course will also cover critical concepts such as unrelated business taxable income (UBTI) and its impact on tax-exempt organizations. Through case studies, including the evolving structure of OpenAI, attendees will gain practical insights into the complexities of nonprofit governance and compliance in a changing legal landscape. This course is designed for legal professionals working with nonprofit organizations, providing them with the knowledge and tools necessary to navigate these intricate legal issues effectively.

Course Objectives
  • Understand the key differences between state charity law and federal tax law as they pertain to nonprofit and for-profit structures.
  • Identify the common elements and requirements for reviewing nonprofit and for-profit transactions.
  • Analyze the implications of joint ventures and for-profit subsidiaries for tax-exempt organizations.
  • Evaluate the impact of unrelated business taxable income (UBTI) on nonprofit entities engaging in for-profit activities.
  • Discuss the evolving structures of nonprofit organizations, including case studies like OpenAI.
Presenter(s)
Ellen Aprill, Rose Chan Loui

*  Some of our resrouces, including on-demand courses, require you to log in or create an account to register and/or access the content.. If you do not already have an account, you will be prompted to create one.
** Before registering for any CLE-eligible course, participants should verify that their jurisdiction permits on-demand and/or self-study CLE, as requirements vary by state and territory.