Interesting.
I wish that we had more of the context. I'm not sure what to make of "the subordinate clubs in your group ruling" but the language that the subordinate clubs are themselves 501(c)(4) organizations implies separate incorporation, which is not the case with most student organizations at educational institutions, in my experience.
In fact, I am coming to doubt whether this has anything to do with educational institutions at all, and suspect that it comes from some sort of social organizations world where a national parent with a charitable purpose qualifies for a 501(c)(3) but its (local?) affiliate clubs have only 501(c)(4) status.
In any cases, it remains true that, for student organizations that operate as part of an educational institution and not as separately-incorporated organizations, contributions to support those student organizations do not qualify as charitable contributions unless the clubs serve exclusively educational (not academic) purpose, under a relatively broad definition of "educational," and with the further proviso that neither limited membership nor the fact that the participants enjoy the activity and association are disqualifying.
So, yes, support of purely social student organizations, at qualified educational institutions, that are not organized for exclusively educational purposes do not qualify as charitable contributions, but I am unconvinced for the moment that this letter adds to that analysis, or, really, that it even has student clubs and educational institutions as its subject!
My US$0.02 worth; the usual disclaimers apply.
Good luck!
Alan
Alan S. Hejnal (he/him)
Data Quality Manager
