Outside Publication

The IRS and Nonprofit Media: A Step Forward Toward Creating a More Informed Public, Council on Foundations

Two-Year Status Report on the Council on Foundations’ Nonprofit Media Project


The Council on Foundations, formed in 1949, is the premier association of grantmaking foundations and corporations in the United States and abroad, and its members drive many of the most important dialogues in philanthropy.

In 2013, the Council on Foundations (Council) released a report titled The IRS and Nonprofit Media: Toward Creating a More Informed Public. The report presented the findings of a working group of nonprofit tax and journalism experts convened at the recommendation of the Federal Communications Commission (FCC) to study whether Internal Revenue Service (IRS) rulings issued in the 1960s and 1970s were hampering efforts by nonprofit media organizations to obtain tax exemption under Section 501(c)(3). The Council’s report found that to be the case and recommended a set of modernized standards for the IRS to apply when ruling on exemption applications for nonprofit media organizations. Among other things, the report recommended that the IRS deemphasize the relevance of operational distinctions between nonprofit and for-profit media organizations in the manner of distribution of content. This is critical since the business models of both nonprofit and for-profit organizations often involve the delivery of free content on the internet—a dissemination tool that did not exist when the original IRS rulings were issued.

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