If I remember correctly, I believe the other requirement is that they also have to be open for any student to join -- not just specific students. But in general, my experience has been as John mentions: the purpose of the club/group has to be educational in nature.
Student clubs might have a staff/faculty sponsor, but in general we classified them as "student-led organizations that offer members opportunities to explore shared interests, develop skills, and engage in activities beyond the formal curriculum." They were open to all currently-enrolled students, regardless of academic discipline.
Are they planning to offer any credit hours for those who participate in the program? If not, I'm inclined to agree that it errs more on the side of a club with volunteered participation versus a truly formal program/"course."
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Taylor Dine
Trust for Public Land
taylor.dine@tpl.org------------------------------
Original Message:
Sent: 04-16-2026 05:42 PM
From: John Taylor
Subject: Intramural/"Club" sports
I think you should look at this a bit differently. The IRS prohibition on charitable gifts to student clubs and groups is not do much about the "student" component, as it is about the "social" aspect. More specifically, the IRS wants to know whether the group exists exclusively for "educational purposes."
You may need to involve University Counsel to determine whether the educational purpose requirement is being met.
John
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