Tax-exempt Organizations Research Articles

Economics And Forensics Of Fraud And Abuse By Tax-Exempt Religious Organizations Versus The First Amendment

<span>This study focuses on the conflict between First Amendment rights of churches and religious organizations and the need by public authorities to investigate and regulate abuses of tax exemptions. The relative lack of accountability of religious organizations opens the door to a number of abusive schemes and scams. Table 1 shows that the IRS has attempted in recent years to improve its ability to enforce regulations pertaining to tax-exempt organizations. Table 2 shows that the number of Tax Exempt tax returns examined by the IRS has increased by 106% from 2005 to 2009, the number of examinations in 2009 still amounted to only 1.24% of returns filed. Table 3 shows that, at the state level, the number of prosecutions and legal actions taken in 2007 by states was a total of 513, just slightly more than 10 per state. Given the obstacles faced by Federal and state enforcement authorities, self-regulation and self-policing by charitable and tax-exempt organizations are likely to be the only way the faithful will receive additional protection against those who would use religion as a tool to mislead them and misappropriate their gifts.</span>

Board Oversight of Community Benefit: An Ethical Imperative

Board oversight of community benefit responsibility in tax-exempt organizations in the nonprofit health care sector is attracting considerable attention. Scrutiny by the IRS and other official bodies has led to stricter measures of compliance with the community benefit standard. But stricter compliance does not sufficiently engage the underlying ethical imperative for boards to provide effective oversight--an imperative that recent research suggests has not been sufficiently honored. This analysis considers why there is a distinctively ethical imperative for board oversight, the organizational nature of the imperative involved, and practical ways to fulfill its obligations. We adopt an organizational ethics paradigm to illuminate the constituent components of the ethical imperative and to clarify emerging benchmarks as flexible guidelines. As these emerging benchmarks enhance board oversight of community benefit they also can shed light on what it means to be a virtuous organization.

Campaign Disclosure and Tax-Exempt Entities: A Quick Repair to the Regulatory Plumbing

This article argues that the are some quick regulatory fixes the Treasury can implement to ensure that tax-exempt organizations (especially 501(c)(4) social welfare organizations) are operating within the rules and that aggressive tax planning is not being used as a way to obfuscate rules designed to require disclosure of contributions and expenditures of political organizations. The article recommends that Treasury promulgate new regulations to require disclosure of contributions and expenditures in excess of $25,000 by tax-exempt entities. The article also proposes that Treasury institute procedures to require tax-exempt organizations to file for exempt status, and to provide procedures for ensuring that these organizations meet the requirements in the statute and are not being used as a mechanism to avoid disclosure provisions in the Internal Revenue Code.

Regulating the Political Speech of Noncharitable Exempt Organizations after Citizens United

The Supreme Court decreed in Citizens United that “[n]o sufficient governmental interest justifies limits on the political speech of nonprofit or for-profit corporations.” Yet the Internal Revenue Code imposes a variety of limits on different categories of tax exempt nonprofits, including tax exempt section 501(c)(4) entities such as Citizens United itself. Supreme Court cases predating Citizens United have justified these tax limits on the grounds that government has no duty to subsidize political speech. The key “no duty to subsidize” authority, Regan v. Taxation with Representation of Washington (TWR), proclaimed, “Both tax exemptions and tax-deductibility are a form of subsidy that is administered through the tax system.” Justice Blackmun concurred. He conceded the point, however, only because such a section 501(c)(3) organization could form a tax-exempt affiliate not subject to lobbying limits (but also not eligible for tax-deductible contributions) under section 501(c)(4). Citizens United, however, rejected the notion that requiring a corporation to establish a corporate affiliate—even an affiliate that is no more than a separate bank account—in order to engage in political speech satisfies the First Amendment, at least for purposes of campaign finance law. This piece will explore both the tax rules that are, and some that might be, applicable to the political speech of noncharitable tax exempt organizations in light of Citizens United. Part I will review TWR, its ancestors and its progeny as well as Citizens United. Part II will describe the current tax rules regarding lobbying and politicking applicable to noncharitable tax exempt organizations. Part III examines the possible impact of Citizens United on the tax law's current approach to political speech. It concludes that Citizens United has not sub silentio overturned TWR. Part IV proposes a number of possible requirements, particularly disclosure requirements, for noncharitable exempt organizations engaged in lobbying and politicking.

Regulating the Political Speech of Noncharitable Exempt Organizations after Citizens United

The role of noncharitable exempt organizations was perhaps the key feature of this year’s election. Senator Baucus as Chairman of the Senate Finance Committee, for example, sent a letter calling upon the IRS to survey major noncharitable 501(c) organizations to ensure that they are obeying the rules regarding political activity, including limits on politicking. In Citizens United, however, the Supreme Court decreed that “[ o sufficient governmental interest justifies limits on the political speech of nonprofit or for-profit corporations.” Nowhere does Citizens United acknowledge the tax limits on political speech or address their constitutionality. Supreme Court cases predating Citizens United have justified these tax limits on the grounds that government has no duty to subsidize political speech. To the extent that “no duty to subsidize” is and remains the justification, nothing in Citizens United explicitly threatens the current tax regime. Nonetheless, we must ask whether the reasoning of Citizens United has undermined Regan v. Taxation with Representation of Washington (“TWR”), the key ”no duty to subsidize” case. In addition, the rules regarding politicking by tax exempt entities have changed significantly since TWR. As a result, the standards as announced in the case and interpreted by its progeny may call for a different conclusion today. Furthermore, this piece will explore both the tax rules that are, and some that might be, applicable to the political speech of noncharitable tax exempt organizations. Part I will review TWR, its ancestors and its progeny as well as Citizens United. Part II will describe the current tax rules regarding lobbying and politicking applicable to exempt organizations that can engage in unlimited lobbying and politicking as part, but not the primary purpose, of their activities: section 501(c)(4) social welfare organization, section 501(c)(5) labor organizations, and section 501(c)(6) trade associations. The discussion will include consideration of treatment of contributions to such organizations for gift tax purposes and the special tax that may be applicable to membership dues because of lobbying and politicking by such organizations. Part II will also review the history of section 527, the section governing political organizations, with particular attention to the 2000 amendments that added registration and disclosure requirements. Part III examines the possible impact of Citizens United on the tax law’s current approach to political speech. It highlights the difference between the definitions of lobbying provided in the Internal Revenue Code and Treasury regulations and the uncertain “facts and circumstances” approach employed by the Internal Revenue Service (“IRS” or “Service”) in identifying politicking. It offers a reconciliation of seemingly contradictory language in Taxpayers With Representation and Citizens United regarding use of affiliates to conclude that Citizens United has not sub silentio overturned TWR’s “no duty to subsidize” holding. It defends, albeit unenthusiastically, the 2000 amendments to section 527. Part IV proposes a number of possible additional disclosure requirements for noncharitable exempt organizations engaged in lobbying and politicking. They include requiring applications for exemption, establishing a new category of exempt organizations for organizations primarily engaged in lobbying and expanding disclosure of contributors for all or for some noncharitable exempt organizations. It also explores the possibility of taxing the politicking expenditures of noncharitable tax exempt organizations not conducted through a separate segregated fund, whether or not the organization has investment income. The piece concludes by reminding us that the tax law regulation cannot substitute for campaign finance regulation.

Taxation of Deferred Compensation: Overview of 409A and 457

The complex rules governing the taxation of deferred compensation are complicated. This article provides an overview of the treatment of nonqualified deferred compensation under Sections 409A and 457 of the Internal Revenue Code of 1986, as amended (the Code). It provides background information about nonqualified deferred compensation plans generally and the enactment of Code Section 409A. The related interpretive guidance issued by the Internal Revenue Service is also described. The general requirements under Section 409A for nonqualified deferred compensation plans are discussed, and the various types of arrangements that are excluded from coverage by these rules are described.The article also provides an overview of Code Section 457, and its application to 457(f) plans and 457(b) plans maintained by governmental employers and tax-exempt organizations.

Pursuing a Tax LLM Degree: Why and When?

This Article and a related article, Pursuing a Tax LLM Degree: Where?, provide information and advice about Tax LLM programs to American law students and JD graduates who are thinking about pursuing a Tax LLM degree. This Article (1) discusses the costs and benefits of pursuing a Tax LLM degree, (2) explains the circumstances in which prospective Tax LLM students may be able to expand their employment options by pursuing a Tax LLM degree, and (3) compiles information and advice that tax law professors typically provide to prospective Tax LLM students in individual counseling sessions. This information includes a primer on tax practice employment opportunities, which vary based on (1) the nature of the work (i.e., transactional work or controversy work) (2) the type of tax subspecialty that is the focus of the tax practice and (3) the type of tax practice employer. The primer includes descriptions of various tax subspecialty areas, including business tax, international tax, estate planning, employee benefits, tax-exempt organizations, and tax controversies. This Article also offers advice to prospective Tax LLM students who are searching for tax positions with various types of employers, including (1) law firms (large, elite law firms, medium-size law firms, or smaller law firms), (2) accounting firms (Big Four accounting firms or smaller accounting firms), (3) the IRS, Treasury Department, or Department of Justice, (4) state taxing authorities, (5) corporations or other organizations, or (6) the U.S. Tax Court. For prospective Tax LLM students who hope to become full-time law professors, this Article also discusses the value of a Tax LLM degree in making the transition from tax practice to academia. In addition, this Article provides information regarding aspects of Tax LLM programs about which prospective Tax LLM students frequently inquire and addresses some common misconceptions about Tax LLM programs.

Regulation of Executive Compensation at Nonprofit Health Care Organizations: Coming Changes?

Executive compensation in health care organizations, particularly tax-exempt organizations, has come under increasing scrutiny in recent years. This paper identifies the implications for tax-exempt health care organizations of recent efforts to regulate executive pay, as well as some changes that the boards of nonprofit health care providers and insurers should consider to minimize the case for further scrutiny and regulation of their executive pay practices.

The role of rating agencies in the market for charitable contributions: An empirical test

Rating agencies play the role of information intermediaries in the market for donations. These watchdog organizations obtain and interpret accounting data and other information about charitable organizations and report ratings to help donors select among the many organizations soliciting contributions. In the age of the internet, information from Internal Revenue Service Form 990 returns prepared by tax-exempt organizations is more readily accessible than ever before. This study examines whether the zero- to four-star ratings provided by Charity Navigator have additional information content for donors. Charity Navigator was selected because its rating system relies almost exclusively on the 990 returns and presumably adds value by incorporating peer-group expectations for various ratios and by presenting straightforward and concise data. Using a random sample of 405 charities rated by Charity Navigator, our results suggest that rating changes do impact contributions. Positive rating changes were associated with an increase in contributions and organizations with a decline in rating were associated with decreased contributions. These effects were in addition to what would be predicted using an efficiency ratio commonly computed from Form 990 accounting data and other control variables.

Intermingling Academic and Business Activities

The growing role of universities in the knowledge economy as well as technology transfer has increasingly been conceptualized in terms of the hybridization of public academic work and private business activity. In this article, we examine the difficulties and prospects of this kind of intermingling by studying the long-term trajectories of two research groups operating in the fields of plant biotechnology and language technology. In both cases, the attempts to simultaneously pursue academic and commercial activities led to complicated boundary maintenance, which arose from the conflicting procedures and requirements of the two activities as well as from the double roles assumed by the actors involved. We, thus, argue that the construction of boundaries is not as contingent and strategic as has often been assumed but is built, instead, on the characteristic goals and tasks of the activities in question. Moreover, we suggest that the discussion on university—industry relationships and the entrepreneurial university has by and large neglected the fact that most universities are either public sector entities or tax-exempt organizations thereby being subject to strict rules and regulations that govern the ways in which they may become engaged in commercial activities. Furthermore, several other enduring cultural features, such as the university’s commitment to open scholarly communication, make the boundary between university and commerce relatively stable. As a consequence, the results of this study lend support to the thesis according to which boundaries in science are not always created at will but reflect the long history and multifaceted societal relevance of this particular institution. This in turn implies that the commodification of university research is bound to be more difficult than what the proponents of the entrepreneurial university seem to assume.

Tax-Exempt Hospitals and Community Benefits: A Review of State Reporting Requirements

In June 2007 the Internal Revenue Service proposed a major overhaul of its reporting requirements for tax-exempt hospitals and released draft Form 990 (the IRS form filed by tax-exempt organizations each year). In December 2007 the IRS promulgated the final Form 990 after incorporating some of the recommendations made in the almost seven hundred public comments on the discussion draft. One recommendation adopted in the final Form 990 is the postponement until tax year 2009 (returns filed in 2010) of the requirement for hospitals to submit detailed information on the percentage of total expenses attributable to charity care, unreimbursed Medicaid costs, and community-health improvement programs (the discussion draft required this information for tax year 2007). Although the IRS will not require tax-exempt hospitals to provide detailed information about community benefits until the 2009 tax year, sixteen states have laws requiring tax-exempt hospitals to enumerate the benefits that they provide to the community. Information about the impact of these laws on the provision of community benefits (e.g., charity and uncompensated care) is examined in this study whose primary purpose is to highlight information policy makers may glean from states that have adopted community-benefit reporting laws.

Mapping the Size and Scope of a Nonprofit Media Sector: The Case of Magazine Publishing

The nonprofit sector of the American media is a vast but little-explored, little-understood segment of the industry. This paper examines the magazine publishing activities of tax-exempt organizations in the United States, drawing on a variety of sources to show that nonprofit publishers represent a large and stable sector of the overall magazine industry, exceeding the number of for profit publishers and accounting for more than 7% of advertising revenue. Roughly half of the advertising revenue is earned by 100 organizations.

Tax-Exempt Organizations and Nonarticulation: Estimates Are No Substitute for Disclosure of Cash Provided by Operations

SYNOPSIS: Not-for-profit entities’ audited financial statements are considered proprietary information, but the World Wide Web provides easy access to financial information from Form 990, the information return filed annually with the Internal Revenue Service. However, Form 990 return does not include potentially useful information for donors, creditors, and regulators such as cash provided by operating activities. Because of articulation of financial statements inherent with the double-entry system, it is theoretically possible to derive operating cash flows from revenues, expenses, and balance sheet accounts that are included on the return. The objective of this study is to determine whether cash from operations can be accurately calculated from Form 990 data. Our analysis includes both simple and more elaborate formulas because complexity may reduce potential usefulness even if accuracy increases. Using 254 observations from two industry groups (higher education and conservation/environmental protection), we compare five formulas. The mean absolute percentage errors of our computations were extremely large for all formulas. Even the formula with the smallest errors produced an amount for cash from operations that was correlated with the actual number for only one of the two industries. The paper also describes articulation problems encountered when a small subsample was examined in more detail. As with similar studies of business entities, it appears that an accurate estimate of cash flow from operating activities cannot be derived from the other financial statements. Therefore, based on the results of this study we recommend that Form 990 should be revised to include selected information from the cash flow statement.

3HO/Sikh Dharma of the Western Hemisphere: The ‘Forgotten’ New Religious Movement?

AbstractThis article will give a general overview of a Sikh movement that originated in the 1960s with an immigrant from India known as Harbhajan Singh, a Khatri Sikh. His initial aim was to teach yoga in Canada, but the job he was promised did not materialize, and thus it was that he turned his attention towards California. In Los Angeles, he took on a new name, Yogi Bhajan, and soon surrounded himself with eager students. An ashram was built soon thereafter and by 1969 his ‘Healthy, Happy, Holy’ group was incorporated as a tax exempt organization. Although Bhajan was from a traditional Sikh family, he increasingly focused on Kundalini Yoga and Tantra in his teaching and practices. However, Sikh teachings were also incorporated into his message, a message that was largely directed towards a white, middle‐class, counter‐culture audience. Needless to say, the Punjabi Sikh community has had a mixed reaction to the ‘Gora’ (white) converts, particularly with regard to the accretions and modifications to the Sikh traditions, upheld by Bhajan and his followers. This article will address aspects of 3HO (or Sikh Dharma in the Western Hemisphere) in its current manifestation that resembles characteristics of new religious movements, particularly its claims to universality and purity within its own manifestation of ‘true’ Sikh identity.

Is it 'Charitable' to Discriminate?: The Necessary Transformation of Section 501(C)(3) into the Gold Standard for Charities

With federal subsidies to organizations exceeding $232 billion for fiscal years 2007 to 2011, the public benefit conferred by such organizations is an increasingly hot topic for Congress, the Internal Revenue Service and the entire nonprofit sector. Despite the national debate over nonprofit versus for-profit hospitals and excessive executive compensation, and the call for stricter governance and regulation, one recurring activity of charities appears to fly under the radar of reformers - discrimination. As illustrated in real-life occurrences contained in pages 3 and 4 of the article, seemingly widespread discrimination by charities exists not only with respect to employment, but more importantly in providing services or engaging in activities for which the organization was originally granted tax-exempt status (e.g., education). The primary bases for such discrimination are currently sexual orientation and marital status.This article contends that these instances of discrimination are intrinsically incompatible with such organizations' charitable purpose and mission, and with society's notion of what constitutes a charity. This article contends that such organizations should not continue to enjoy the benefits of tax-exempt status if they engage in discriminatory practices or maintain discriminatory policies. To combat such discrimination, this article proposes the inclusion of an expansive nondiscrimination requirement within Section 501(c)(3). Such a requirement ensures that the stream of tax-deductible dollars (generated by the contributions deduction) received by charities is not used to discriminate against any member or segment of society. The proposal transforms Section 501(c)(3) into the gold standard for all tax-exempt organizations, ensuring that their beneficiaries are as diverse and all encompassing as the taxpaying public from whom such organizations draw their support.

Taxation of pentecostal churches in Africa: paradigm of pentecostals in Uganda

The study sought to determine if Pentecostals in Uganda were qualified to maintain their status quo as tax exempt organizations considering their vast financial resources. The study also investigated the impact of such exempt status on the principle of equality. Purposive sampling technique was used to draw a sample of 250 and they were categorized into membership structure in four districts (Kampala, Kira, Luwero and Mukono). Descriptive survey design was employed for the study. Also, descriptive and inferential analyses were used. The findings revealed two distinct opinions with regard to taxation of Pentecostals. First, the Pentecostal members indicated that Pentecostals should not be taxed. Second, non-members of Pentecostals opined that they should be taxed. With regard to the principle of equity, the findings also identified two different considerations. First, maintaining the status quo of Pentecostals tax wise was considered as tax inequality between Pentecostals and business organizations in the country. Second, taxation of Pentecostals without taxation of other faith based institutions in the country was also considered as tax inequality. Recommendations were made that the revenue authority should screen all environmental variables in their tax planning process before the derivation of tax policy with regard to taxation of Pentecostals in the country. Also, numbers of other recommendations have been made based on the findings. Key words: Business, pentecostals, public character, taxation, tax equality.

Truth as a Value in the Grants Process

For librarians and information scientists-whether they are conducting grants research for faculty, writing proposals to support their institution's projects, or serving as a grant's project director-there are ethical issues to be dealt with throughout the grants process. One ethical challenge is to always tell the truth. Truth must be a value throughout, from the start of the grant seeking process, in the writing of the proposal, during the grant's administration and evaluation, and in the filing of a final report to the funding entity.What Is Truth?According to Wikipedia, dictionary definitions of truth mention some form of accord with fact or reality. There is, however, no single definition of truth about which scholars agree, and numerous theories of truth continue to be widely debated. Differing opinions exist on such questions as what constitutes truth, how to define and identify truth, and whether truth is subjective, relative, objective, or absolute. The purpose of this article is to discuss truth as a value in the grants process, rather than to debate the philosophical issues involving the concept. For the purposes of this discussion, truth shall be defined as the quality of being accurate and in accord with reality.Why Is Truth Important throughout the Grants Process?A grant award is a legal contract, not a gift. It is used to fund the activities described in the winning proposal that start after the contract is signed. Grants are not free money. Foundations and other grant makers are organizations with missions and goals similar to those of the grant seeker. Foundations and other grant makers award grants because the seeker is proposing a plan for the requested money that closely matches the foundation's own goals, initiatives, and dreams. Grant makers, such as government agencies, foundations, and corporations, award grants to fund solutions to problems. The foundation has money it wishes to use for a particular purpose. The seeking organization is capable of doing the work that is of interest to the foundation. That organization and its proposed grant project have a value that is equal to the grant money. Once awarded, the grant contract will specify the rules that must be followed in order to remain in compliance with the terms of the contract. These rules cover reporting instructions, spending policies, and records retention requirements.The First Truth: The Test of EligibilityAn organization or institution must be legally eligible to receive a grant from the grant maker. Grant makers must award their funds to the appropriate organization with the appropriate legal status or suffer penalties. The most common way to determine an organization's legal status is to refer to the formal determination made by the Internal Revenue Service. A nonprofit that has been legally established in one of the fifty states must obtain recognition as a charitable organization from the IRS in order for contributions to it to be tax deductible. Section 501(c)(3) of the Internal Revenue Code (IRC) covers those tax-exempt organizations that are organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes... and are eligible to receive tax-deductible contributions. An organization that meets the definition of Section 501(c)(3) is then measured against Section 509(a) of the IRC, which declares that a 501(c)(3) organization is presumed to be a private foundation unless it can demonstrate that it falls into one of four categories of organizations:* Organizations described in Section 170(b)(1)(A), which covers churches; schools, colleges, etc.; hospitals, medical research institutes, etc.; support organizations to educational institutions; governmental units; and publicly supported organizations (including community foundations);* Organizations that normally receive more than one-third of their support from gifts, grants, fees, and gross receipts from admissions, sales, etc. …

Tax-Motivated Expense Shifting by Tax-Exempt Associations

Tax-exempt organizations are subject to the Unrelated Business Income Tax (UBIT) on the profits of business activities unrelated to their exempt mission. This study extends recent research on the expense allocations of charitable nonprofit organizations by examining a group of noncharitable nonprofits—primarily trade, labor, and agricultural associations—that differ from charitable nonprofits on a number of dimensions. The paper tests for tax-motivated expense shifting by associations. Data is obtained from the IRS Statistics of Income Division, and is supplemented by data requested from associations. Reported unrelated business expenses are compared to those predicted by a regression model to estimate expense shifting. Associations are estimated to shift approximately 20–21 percent of the expenses reported on their UBIT returns. Further analysis calls into question the validity of the estimation model, and suggests that expense shifting may be understated in this and previous studies.

The Myth of 527 Organizations

527 organizations have been and continue to be an expedient medium for regulation of political activities. 527's have had a bad press, being commonly depicted as tax exempt havens through which big money may flow - outside of ordinary strictures such as those of the Federal Elections Campaign Act - into political campaigns. Thus regulation, such as that of the 2000 Act ... to require 527 organizations to disclose their political activities or The 527 Reform Act of 2005 now pending in Congress, is seen as necessary. Regulation of this sort falls on speech ordinarily subject to constitutional protection. However, inasmuch as a tax exemption is a public subsidy, Congress, it is thought, may here regulate free of ordinary First Amendment constraints, according to the axiom that Congress has no duty to subsidize speech. These suppositions respecting 527's are, however, misleading to false. 527 organizations are associations subject to taxation under Sec. 527 of the Internal Revenue Code. This section was enacted in 1975 not to exempt these associations from taxation but to identify and tax their income, which income usually consists of interest earned on deposited funds (dues and contributions). Dues and contributions themselves were not taxed, not because they were exempted from taxation but because these items - consistent with history, practice, and economic theory - are not income. Thus, 527's are not tax-exempt organizations, they do not feed at the public trough, and they should not be removed from ordinary First Amendment protection according to the axiom that Congress has no duty to subsidize speech. Also, 527's are not exempt from ordinary regulation, as that of FECA. Numbers of them are subject to FECA and routinely comply with its disclosure requirements. On they other hand, a number of 527's are not subject to FECA, not because they are 527's but rather because of First-Amendment driven limits (respecting issue advocacy and political committees) to the coverage of that Act. The First Amendment, then, is the loophole, not 527's. In the end, 527 is a neutral tax classification and a 527 organization is simply an association involved in electoral politics, local, state, or federal, that has over $100 in interest income on deposited funds. This includes smallish organizations, earnestly involved in advocacy of various sorts, from local school bonds to conservation issues. These 527's are not of the secret slush fund model offered for 527-based regulation. They are of the civic-minded, civic-building model that ordinarily enjoys First Amendment protection.

Comparing Faith-Based and Secular Community Service Corporations in Pittsburgh and Allegheny County, Pennsylvania

Much of the national dialogue regarding the role of faith-based organizations (FBOs) in social service delivery has focused on congregations that provide various types of services to their communities. Comparatively little attention has been given to FBOs that have incorporated independently as 501(c)3 tax-exempt organizations. This survey of 237 community service organizations in Pittsburgh and Allegheny County, Pennsylvania, finds that a substantial amount of service is provided by agencies that consider themselves to be FBOs, which are comparable to their secular counterparts in many respects, such as size, funding, program capacity, and management sophistication. FBOs appear to be substantially different from secular agencies with respect to their extensive use of volunteers, their relatively low reliance on government funding, and their relatively low engagement in policy advocacy and lobbying.