Why Are Nonprofits Exempt From the Corporate Income Tax?

Abstract

This article considers the nonprofit exemption from the corporate income tax (CIT), which has typically been justified with either subsidy or base-defining reasons. A different rationale is introduced: The corporate tax as applied to for-profit businesses is meant to capture in the tax base income ultimately owned by individuals that might otherwise escape tax, and the nonprofit exemption is a consequence of nonprofit income`s not being attributable to any individual. To explain why nonprofits are exempt from the CIT, scholars should begin by asking why there is a CIT at all rather than by asking what is so special about nonprofits. The argument is then applied to the debate over the rationale for the unrelated business income tax.