As many of you know, this is a topic where John and I differ, at least in emphasis.
Student clubs and societies may qualify for exemption under IRC 501(c)(3) if they serve exclusively educational purposes, even if they offer incidental social or recreational activities.
"Educational," in turn, relates to "(a) the instruction or training of the individual for the purpose of improving or developing his capabilities; or (b) the instruction of the public on subjects useful to the individual and beneficial to the community."
Greek Social Organizations, which were a common question, are specifically addressed as not serving exclusively educational purposes, but other student organizations are not specifically addressed, which leaves us (with counsel) to make an evaluation.
I would argue that it's important to note that the term is "educational" not "academic." Might club sports be organized for "the purpose of improving or developing the participant's capabilities"? A debating club? An a cappella music group? A business club of one sort or another? Are there clubs organized "to provide instruction of the public on subjects useful to the individual and beneficial to the community?" I would want to argue that such clubs might meet the standard.
The attached document addresses these topics at somewhat greater length, with references.
My US$0.02 worth; the usual disclaimers apply.
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Alan S. Hejnal (he/him)
Smithsonian Institution
Washington DC
hejnala@si.edu------------------------------
Original Message:
Sent: 10-08-2025 02:54 PM
From: John Taylor
Subject: Club or Campus Organization Fundraising
As you probably know, the IRS disallows tax deductions for gifts to most student clubs and organizations. Therefore, the Advancement Office must serve as a clearing house to ensure any fundraising activities outside of Advancement are coordinated and conducted with the appropriate language regarding the non-deductibility of some contributions.
What you are looking for is a "Third Party Fundraising Policy" that addresses both internal and external groups wishing to engage with your donors and prospects. While I have written dozens of these, you will find many in the interweb using this search string: site:.edu "Third Party Fundraising"
John
John H. Taylor, PrincipalJohn H. Taylor Consulting, LLC
2604 Sevier Street
Durham, NC 27705
919.816.5903 (cell/text)
Serving the Advancement Community Since 1987
Original Message:
Sent: 10/8/2025 3:46:00 PM
From: Mary Taylor
Subject: Club or Campus Organization Fundraising
Good afternoon,
We are trying to address Club Sports and Campus Organization fundraising and we want to write a comprehensive policy for this purpose. Would anyone be willing to share their policy on this, or at least a portion of their policy? Or, if you have tips and ideas about this subject, I would be grateful for your input.
Thanks so much,
Mary
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Mary Taylor
Lees-McRae College
taylorm@lmc.edu
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