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Tax-Exempt Organizations

Miles & Stockbridge represents and provides tax advice to significant tax-exempt organizations throughout the United States, including public charities and private foundations, charitable organizations, hospitals, educational institutions and governmental agencies.  Our primary focus is to help our nonprofit clients secure and maintain their tax-exempt status under the Internal Revenue Code. 

Because many tax-exempt organizations have operations that generate taxable revenue, one aspect of our counsel to them involves the tax treatment of unrelated business income.  We also assist nonprofits, such as hospitals, with related issues like the tax treatment of divesting for-profit subsidiaries and divisions and of mergers or joint ventures with other nonprofit or for-profit organizations, including the tax effect of these transactions on employee benefit plans. 

An important part of our work with tax-exempt organizations involves legal consideration of their organizational form and structure.  We handle applications to the IRS for tax-exempt status, secure letters of determination and respond to audits and inquiries.  In addition to forming charitable lead trusts and charitable remainder trusts to handle the deductibility of gifts to various charitable organizations, we advise on the creation of 501(c)(3) organizations as public charities. Our lawyers work with such issues and their tax implications on a regular basis and advise on the appropriate deductibility.

Miles & Stockbridge provides tax-exempt bond counsel to health care organizations, educational institutions and municipalities.  We have served as bond counsel to the State of Maryland and its agencies for more than 30 years and have handled virtually every type of municipal debt.  The goal of our bond counsel services is to minimize taxes, maximize collateral value and reduce lender risk, while working to achieve the public purposes of tax-exempt financing.