The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement. Bruce R. Hopkins

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p. 254, note 165. Insert following existing text:

      An individual selling religious merchandise by means of the internet was found liable for federal income tax on the net proceeds, with a court rejecting his argument that he was functioning as a church (Lloyd v. Comm'r, T.C. Memo. 2020‐92 (2020).

      (c) Principle of Respect for Autonomy

       p. 262, note 219, second line. Insert following third period:

      The Court expanded the ministerial exception to encompass teachers employed by religious schools (Our Lady of Guadalupe School v. Morrissey‐Berru; St. James School v. Darryl Biel, 140 S. Ct. 2049).

       p. 263, note 233. Delete 26.9 and insert 26.11.

       p. 266. Insert as second complete paragraph, before heading:

      1 27.1 Espinoza v. Montana Department of Revenue, 140 S. Ct. 2246 (2020).

      2 252.1 Priv. Ltr. Rul. 201904008.

        § 11.2 Amateur Sports Organizations

        § 11.8 Donor‐Advised Funds (c) Portrait of Donor‐Advised Fund Universe

        § 11.9 Endowment Funds (b) College and University Endowment Tax

       p. 273, note 18. Delete last sentence and insert:

      The IRS ruled that an entity conducting outboard motor boat races (without the participation of amateur athletes) open to the public and an entity conducting professional rodeos are not qualified amateur sports organizations (Priv. Ltr. Ruls. 201933016, 201706019).

       p. 281. Insert following second complete paragraph, before heading:

      Total estimated charitable contributions in the United States in 2018 were $427.71 billion (see the September 2019 issue). Of this amount, $292.09 billion came from individuals (68 percent). Thus, donors to donor‐advised funds accounted for 12.7 percent of individual giving. Contributions to DAFs expressed as a percentage of total annual individual giving have steadily increased during 2010–2018.

      Contributions to donor‐advised funds in 2018 increased by 20.1 percent in relation to the total for 2017. Grants from these funds to charitable entities amounted to an 18.9 percent increase from the total for 2017. Assets under management in donor‐advised funds increased by 8.3 percent compared to the value in 2017. The number of these funds “increased sharply,” rising by 55.2 percent in 2018. The payout rate for donor‐advised funds in 2018 was 20.9 percent.

      The average size of a donor‐advised fund in 2018 is estimated to be $166,653. This is a 30.2 percent decrease compared to the 2017 number ($238,857). The NPT report states that the “emergence of workplace giving donor‐advised fund accounts and sponsoring organizations that have no or low contribution minimums will continue to drive down the average donor‐advised fund size.”

      The NPT report includes a comparison of donor‐advised funds from the standpoint of type of sponsoring organization. Noting that there are about 1.33 million “registered” public charities in the United States, the charities tracked in the report comprise less than 1/10th of 1 percent of these organizations. The report offers this overview: (1) the number of donor‐advised funds sponsored by national charities exceeds the number of accounts at the other two types of sponsoring organizations combined, (2) the national charities have higher aggregate charitable asset values and distribute more grant dollars, (3) the average donor‐advised fund asset size at community foundations is higher than at the other two types of sponsoring organizations, and (4) single‐issue charity sponsors have the highest payout rate.

      The NPT report includes data from 54 national charities.

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