Amend16RobertWirengard - Page 12

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                                     Discussion                                       
               Section 501(a) exempts from Federal taxation organizations             
          described in section 501(c)(3).5  To qualify as an organization             
          described in section 501(c)(3), an organization must satisfy each           
          of the following four requirements:  (1) It must be organized and           
          operated exclusively for certain specified exempt purposes; (2)             
          no part of its net earnings may inure to the benefit of a private           
          shareholder or individual; (3) no part of its activities may                
          constitute intervention or participation in any political                   
          campaign on behalf of any candidate for public office; and (4) no           
          substantial part of its activities may consist of political or              
          lobbying activities.6  See sec. 501(c)(3); Fla. Hosp. Trust Fund            

               5SEC. 501(a).  Exemption from Taxation.--An organization               
          described in subsection (c) * * * shall be exempt from taxation             
          * * *.                                                                      
               6SEC. 501(c).  List of Exempt Organizations.--The following            
          organizations are referred to in subsection (a):                            
                         *    *    *    *    *    *    *                              
                    (3) Corporations, and any community chest, fund, or               
               foundation, organized and operated exclusively for                     
               religious, charitable, scientific, testing for public                  
               safety, literary, or educational purposes, or to foster                
               national or international amateur sports competition (but              
               only if no part of its activities involve the provision of             
               athletic facilities or equipment), or for the prevention of            
               cruelty to children or animals, no part of the net earnings            
               of which inures to the benefit of any private shareholder or           
               individual, no substantial part of the activities of which             
               is carrying on propaganda, or otherwise attempting, to                 
               influence legislation (except as otherwise provided in                 
               subsection (h)), and which does not participate in, or                 
                                                              (continued...)          





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