Client AlertsNonprofitKey Considerations for Creating a For-Profit Subsidiary of a Public Charity
By Elizabeth Manchester, Russell Stein, Brian Reilly, and Madeline Ursini OpenAI, an artificial intelligence research nonprofit, has recently garnered media attention for considering a restructuring strategy involving the formation of a taxable subsidiary. The establishment of for-profit taxable subsidiaries by nonprofit organizations qualified as tax-exempt under Internal Revenue Code (“IRC”) Section 501(c)(3)[1] has been a...