Reforming Nonprofit Exemption Requirements

70 Pages Posted: 31 May 2011 Last revised: 28 Jun 2014

See all articles by Peter Molk

Peter Molk

University of Florida Levin College of Law

Date Written: 2012


This Article proposes a reform for nonprofit exemption and unrelated business income tax. Current tax law provides unclear guidance and requires exempt organizations to risk their entire exemptions on this guidance, leading them to make the socially inefficient choice to use for-profit subsidiaries to preserve their exemptions. Reforming the tax law will solve this inefficiency while providing exempt nonprofits with the desirable option to undertake efficient nonexempt activities to augment their operating budgets. This reform is particularly important in light of changes to the healthcare field; reform will enable exempt healthcare organizations to offset rising health costs and decreased reimbursements with other revenue opportunities.

Keywords: nonprofit, UBIT, tax, corporate organization

JEL Classification: H21, H25, H40, H41, K34, l30, l31

Suggested Citation

Molk, Peter, Reforming Nonprofit Exemption Requirements (2012). Fordham Journal of Corporate and Financial Law, Vol. 17. Available at SSRN:

Peter Molk (Contact Author)

University of Florida Levin College of Law ( email )

P.O. Box 117625
Gainesville, FL 32611-7625
United States

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