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1 Scott Hodge, Reining in America's $3.3 Trillion Tax-Exempt Economy 1 (2024)

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* TAX FOUNDATION



Reining in America's $3.3 Trillion

Tax-Exempt Economy




Scott Hodge    President Emeritus   & Senior Policy Advisor

June 2024



Key Findings

•   For over a century, lawmakers have exempted politically favored organizations and industries from
   the tax code. As a result, the tax-exempt nonprofit economy now comprises 15 percent of GDP, spans
   more  than 1.8 million organizations, and manages over $8 trillion in assets. In 2019, it pocketed more
   than $238 billion in net income.
 • The tax-exempt  sector is overdue for review and reform. The U.S. needs a principled, rules-based
   approach  to 1) distinguish between benevolent organizations and tax-exempt businesses, and 2) level
   the playing field between the business activities of nonprofit and for-profit entities.
 •  Many industries exempted from the income tax were designated as such in the Wilson-Gorman Tariff
   Act of 1894 and the Tax Act of 1909, but they reflect the social norms of the 19th century, not our 21st
   century economy.
 • The  majority of tax-exempt organizations today are business-like in form and function, including credit
    unions, hospitals, utilities, insurance companies, universities, professional athletic associations, golf
    clubs, and consulting firms, to name a few.
 •  Business-like income has been the fastest growing source of income for 501(c)(3) tax-exempt orga-
    nizations over the past 30 years, now accounting for 71 percent of their income. Charitable donations
    make up just 12 percent of nonprofit income.
 •  More than half (55 percent) of all the income generated by 501(c)(3) organizations comes from tax-ex-
   empt  hospitals and health-care plans. The largest nonprofit in America is Kaiser Permanente. Kaiser's
   health plan, hospitals, and state health plans generated over $110 billion in revenues in 2019.
 •  In 2019, there were 325 501(c)(3) nonprofits with more than $1 billion in revenues-nearly all of which
   are hospitals and universities.
 • The  unrelated business income tax (UBIT) rules that were intended to rein in tax-exempt businesses
    have become toothless and have allowed the growth of large nonprofit businesses.
 • A reasonable rewriting of the tax-exempt rules should include narrowing the definition of public char-
    ity and subjecting all non-charitable income to the corporate tax rate of 21 percent. Doing so could
    raise nearly $40 billion annually in new tax revenues.

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            For over 80 years, our mission has remained the same: to improve lives through tax policies that lead to greater economic growth and opportunity.
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