# Converting club from 501c7 to 501c4



## rrewert (Feb 8, 2010)

Does anyone know what is involved in changing a retriever club's non-profit organization type from a 501c7 to a 501c4?


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## DarrinGreene (Feb 8, 2007)

why, just curious, would you want to be a political action organization?


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## rrewert (Feb 8, 2010)

DarrinGreene said:


> why, just curious, would you want to be a political action organization?


Clubs income source is not compliant with the income source limits for a 501c7.


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## john fallon (Jun 20, 2003)

Why not a 501c3 ?

john


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## rrewert (Feb 8, 2010)

A C3 might be better. Any idea in what is involved in making this change? Does a change like this normally require legal help?


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## stonybrook (Nov 18, 2005)

Rod -

Get ahold of Dave Bunde. He lives in the Twin Cities, runs and judges AKC HT's and has helped a couple clubs with this I believe.

FWIW - I do recall hearing people say that you will want to include everything you can about your club that pertains to "education" when submitting your application.

Travis


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## Eric Johnson (Dec 23, 2004)

I sense that you're not an accountant. Perhaps you'll get more help if you describe the problems with your current 501(c)7 status. There's a wealth of information available here but you sort of need to start from the beginning.

Eric

John-There are perhaps two or three clubs in the country that are 501(c)3. One is in Alaska. The IRS has sort of cut off that status for retriever clubs. As I recall the Alaska situation, they wrote an in-depth mission statement that leaned on public education.


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## john fallon (Jun 20, 2003)

Eric Johnson said:


> I sense that you're not an accountant. Perhaps you'll get more help if you describe the problems with your current 501(c)7 status. There's a wealth of information available here but you sort of need to start from the beginning.
> 
> Eric
> 
> John-There are perhaps two or three clubs in the country that are 501(c)3. One is in Alaska. The IRS has sort of cut off that status for retriever clubs. As I recall the Alaska situation, they wrote an in-depth mission statement that leaned on public education.


Do you know who either of the others are ?

john


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## Eric Johnson (Dec 23, 2004)

Haven't a clue who the others are. The Alaskan club should be pretty easy to pin down. One of the others may be a club in the upper midwest....Blackhawk maybe? I looked into all of this in my pre-stroke days and recovery of those memories just never rose to any level of importance.

I'm merely curious as the Toller club is a 501(c)7. We had a really good corporate attorney look at our choices. The (c)7 was his clear instruction. 

There's a lot of misconception about political action by a (c)7. I don't recall the exact test(s) but the (c)7 can be involved in some political activities if they simply advocate the club's purposes. IOW, we are a dog club and this or that legislation is not in the best interests of the sport of dogs.

Eric


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## rrewert (Feb 8, 2010)

Eric Johnson said:


> Haven't a clue who the others are. The Alaskan club should be pretty easy to pin down. One of the others may be a club in the upper midwest....Blackhawk maybe? I looked into all of this in my pre-stroke days and recovery of those memories just never rose to any level of importance.
> 
> I'm merely curious as the Toller club is a 501(c)7. We had a really good corporate attorney look at our choices. The (c)7 was his clear instruction.
> 
> ...


Gentlemen

Our concern with the (c)7 is the limits on income from external sources (non members). If we read the limits correctly no more than 15% of the clubs total income can come from non club members. So if your club is holding events that are open to non members (like an AKC Hunt Test or Training Seminars) it is highly likely that your income from non members will exceed the 15% limit.


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## junbe (Apr 12, 2003)

There are currently 3 retriever clubs that conduct AKC field trials that are 501(c)3. All of this information is publicly available, together with their 990 tax form. As well as the club in Alaska, the other two are Duluth Retriever Club and Blackhawk Retriever Club. To become a 501(c)3, total cost in time involved for the Blackhawk Club was 3 years with an attorney doing research and a CPA and over $3,000 in expenses. Very few clubs can meet the stringent requirements for this classification, which includes documentation of prior committment. It does take an ongoing time commitment and expense to file the proper forms and meet other requirements. We spend over $1,000 a year to maintain this status.

See our club website: http://www.blackhawkrc.org/


Jack


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## Eric Johnson (Dec 23, 2004)

The 15% is but one limit.

You might look at what is called "Unrelated Business Income". This may help you deal with this issue. This allows you to "sub-divide" your income and pay only on this portion.

I doubt that a hunt test with 100 entries of which 60 are non-club members would trip any interest on the part of the IRS. You'll still need to file a Form 990. As long as all the income from the test is reported, I doubt that you'd have any problem.

It's an interesting problem. See: http://www.irs.gov/charities/index.html?navmenu=menu1



Eric


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## captainjack (Apr 6, 2009)

From the IRS...
"Social Clubs – Requirements for Exemption – Support By Membership Dues 

A social club must be supported by membership fees, dues, and assessments. *A section 501(c)(7) organization may receive up to 35 percent of its gross receipts, including investment income, from sources outside of its membership without losing its tax-exempt status. *No more than 15 percent of the this amount may be derived form use of the club’s facilities or services by the general public or from other activities not furthering social or recreational purposes for members. If an organization has non-member income exceeding these limits, all the facts and circumstances will be considered in determining whether the club continues to qualify for exemption ."

The first sentence says that "A social club must be supported by membership fees, dues, and assessments" and I don't think test/trial entry fees of members would be considered "membership fees, dues, and assessments."

I don't see how any club that holds a trial or test can meet the 35% of gross receipts test. 
If someone knows how, please provide an example with the math.


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## Joe Brakke (Jul 3, 2008)

We have investegated this issue and here is a reply from another club that has filed correctly.

Clubs can file as exempt from Federal income tax under section 501(c) (7) of the Internal Revenue Code and we file Form 990-N each tax year electronically. If your club is not tax exempt I would recommend that you apply for such status. The application requires considerable paper work and $750.


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## captainjack (Apr 6, 2009)

Joe Brakke said:


> We have investegated this issue and here is a reply from another club that has filed correctly.
> 
> Clubs can file as exempt from Federal income tax under section 501(c) (7) of the Internal Revenue Code and we file Form 990-N each tax year electronically. If your club is not tax exempt I would recommend that you apply for such status. The application requires considerable paper work and $750.


Who said they filed it correctly? The club?

I know a guy who used to claim his dogs as dependents on the form 1040 he filed each tax year. Do you think that was correct and legal?

The HRC, Inc. is organized as both a 501c7 and 501c3 (the two are actually legally separate entities). Why do you think that is?

I don't think anyone will be able to show the math where the club meets the IRS's 35% test for a 501c7. I could be wrong but...


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## DarrinGreene (Feb 8, 2007)

Hmmm, how do you account for the revenue and expenses of the test outside the club P&L so that only the resulting profit is viewed as income to the actualy tax exempt organization?


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## captainjack (Apr 6, 2009)

While I think organizing as a 501c7 would not work for a club holding tests/trials, I don't see an issue with organizing as a 501c3.

You can have raffles, fund raisers, etc. without losing your exempt status. You hold a few training days a year and put on a seminar or two and you are complying with the "educational" purpose.

Both 501c7 and 501c3 organizations must file with the IRS annually.

Does anyone see a problem with the organizing as a 501c3?


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## captainjack (Apr 6, 2009)

DarrinGreene said:


> Hmmm, how do you account for the revenue and expenses of the test outside the club P&L so that only the resulting profit is viewed as income to the actualy tax exempt organization?


The 501c7 35% test is not a profit test it is a gross receipts test. That is why I don't believe that any club that holds a test/trial can meet it.


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## Eric Johnson (Dec 23, 2004)

No dog club beyond the three mentioned will succeed in a 501(c)3 application. The IRS looks really closely at these applications and a retriever club just won't pass muster. The organization must be created for the purposes "...set forth in section 501(c)(3) are charitable, religious, educational, scientific, literary, testing for public safety, fostering national or international amateur sports competition, and preventing cruelty to children or animals. "

The HRC has incorporated a 501(c)3 for charitable donation purposes in furtherance of the above. They must be a completely separate organization. Thus, dues go one way and donations to support health research go another. I wanted to set up the Toller club the same way and put our rescue and health programs under a 501(c)3. That way the 501(c)7 could donate to the 501(c)3 any "profits" and reduce our exposure while providing the membership with a way to make tax free donations.

However, if you want to proceed with a 501(c)3, be sure and report back on how it works out for you. Lots of folks here will be interested. It will probably cost a couple thousand to do it as you will probably need to amend your bylaws and articles of incorporation ... which will mean a new filing with the state Sec of State. Legal fees will eat up most of the cost.

Eric


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## captainjack (Apr 6, 2009)

Eric Johnson said:


> No dog club beyond the three mentioned will succeed in a 501(c)3 application. The IRS looks really closely at these applications and *a retriever club just won't pass muster*. The organization must be created for the purposes "...set forth in section 501(c)(3) are charitable, religious, *educational, *scientific, literary, testing for public safety, fostering national or international amateur sports competition, and preventing cruelty to children or animals. "
> 
> The HRC has incorporated a 501(c)3 for charitable donation purposes in furtherance of the above. They must be a completely separate organization. Thus, dues go one way and donations to support health research go another. I wanted to set up the Toller club the same way and put our rescue and health programs under a 501(c)3. That way the 501(c)7 could donate to the 501(c)3 any "profits" and reduce our exposure while providing the membership with a way to make tax free donations.
> 
> ...


I don't have a ton of experience with 501c3s but have prepared a couple tax returns for them. 

I've seen guys who own vintage war era aircraft organized as a 501c3. These guys, IMO, had a hobby of buying and flying old planes. They hold an air show once a year to "educate" the public on vintage air planes, they can raise money etc. to help offset some of the expense of the whole deal. 

Another 501c3 was a soccer club. This was the most similar to our retriever clubs. The parents pay dues to the club and become members, then they hold a series of soccer ternaments each year. Again, with the purpose to "educate" the public about soccer. They have paid staff and coaches and hold fund raisers.

The CPA firm I was with at the time did these returns for no fee, and I'm sure they also helped set them up at no charge.

I'm sure there is an attorney or two in most clubs who would file the paper work with the SOS and draw up new articles of incorporation for little or no charge. 

Why do you think a club wouldn't be able to meet the educational purposes criteria?


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## Eric Johnson (Dec 23, 2004)

captainjack said:


> Why do you think a club wouldn't be able to meet the educational purposes criteria?


Because it's been tried without success. Take note of Jack's description of what Blackhawk went through. We had a similiar experience shaping up and declined to pursue the matter. Instead we went with a 501(c)7 on the suggestion of our tax attorney.

Eric


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## captainjack (Apr 6, 2009)

Eric Johnson said:


> Because it's been tried without success. Take note of Jack's description of what Blackhawk went through. We had a similiar experience shaping up and declined to pursue the matter. Instead we went with a 501(c)7 on the suggestion of our tax attorney.
> 
> Eric


How does your club meet the 35% gross receipts test for the 501c7? Only 35% of gross receipts can be from sources other than member dues.

Our club generates over $40,000 a year in gross receipts of which about $2500 is from memebr dues. So about 94% of our gross receipts are not from member dues. I just don't see how a club can make the math work.

Now if each of our 70 members paid $1,000 a year in dues we'd have gross receipts of $107,500, $37,500 being from sources other than member dues.


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## Zman1001 (Oct 15, 2009)

captainjack said:


> How does your club meet the 35% gross receipts test for the 501c7? Only 35% of gross receipts can be from sources other than member dues.
> 
> Our club generates over $40,000 a year in gross receipts of which about $2500 is from memebr dues. So about 94% of our gross receipts are not from member dues. I just don't see how a club can make the math work.
> 
> Now if each of our 70 members paid $1,000 a year in dues we'd have gross receipts of $107,500, $37,500 being from sources other than member dues.


It does not say specifically membership dues, just non-member sources.

Based on the $40,000, you would have to exclude all entry fees received from members out of that total to come up with the percentage that is from non-member sources.

I still agree with you though, it will be very hard for any club to meet the 35% rule for gross receipts.

I guess the easiest way around it would be to include A $5 membership surcharge to the entry fee (not to increase the entry fee, just classify $5 that way) so that every single person who runs in the trial / tests are considered associate members (The 35% rule says nothing about what type of membership, just membership). So if you would do this, it would mean that everyone who runs in the trial/test are considered members of some sort, so all entry fees for them would be considered member receipts.

Just a thought.


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## Eric Johnson (Dec 23, 2004)

Unrelated Business Income

Eric


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## bjoiner (Feb 25, 2008)

Eric Johnson said:


> Unrelated Business Income
> 
> Eric


UBIT is TAXABLE


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## Eric Johnson (Dec 23, 2004)

Yes. I know that.


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## Ironman (Jan 1, 2008)

Zman1001 said:


> It does not say specifically membership dues, just non-member sources.
> 
> Based on the $40,000, you would have to exclude all entry fees received from members out of that total to come up with the percentage that is from non-member sources.
> 
> ...


I like that idea.
One problem I see though would be that the "members" are potentially paying their membership fee multiple times per year if they enter more than one event.


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## captainjack (Apr 6, 2009)

Zman1001 said:


> ...
> I guess the easiest way around it would be to include A $5 membership surcharge to the entry fee (not to increase the entry fee, just classify $5 that way) so that every single person who runs in the trial / tests are considered associate members (The 35% rule says nothing about what type of membership, just membership). So if you would do this, it would mean that everyone who runs in the trial/test are considered members of some sort, so all entry fees for them would be considered member receipts.
> 
> Just a thought.


I believe the intent of the 35% is from member dues not member test fees but none the less, the everyone is a member idea won't fly.

The 35% is only one of the criteria..

Again from the IRS...

"An essential earmark of an exempt social club is personal contact, commingling, and face-to-face fellowship. Members must share interests and have a common goal directed toward pleasure, recreation, and similar purposes. Fellowship need not be present between each member and every other member, as long as it is a material part in the life of the organization. A statewide or nationwide organization that is made up of individual members, but divided into local groups, satisfies this requirement if fellowship is a material part of the life of each local group.

Example: A flying club was organized to own and operate aircraft suitable for business or personal use by its members, to enable members to improve their flying abilities, and to provide economical flying facilities for members. The club’s sole activity involves owning, operating, and maintaining the aircraft for use by members. Because there is thus little commingling among members for social or recreational purposes, the club does not qualify for exemption under Code section 501(c)(7).
"


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## Ken S. (Feb 2, 2005)

I am fully of the belief that you can qualify as a §501(c)(3) and that there are a number of clubs besides three that have that designation. Also, that vast majority of clubs that host horse shows and related events are 501(c)(3). The cost on an annual basis should be no more than any other non profit. There would be some legal work involved in changing, as you would likely need to change your charter and bylaws. These documents figure heavily in the determination process. There are quite a number of advantages with the 501(c)(3) designation as the clubs, within limits (mainly you can not be a "disqualified person" and give large amounts), could get deductible donations. On the other hand, if you are too worried about it, just be a "C" corporation and pay your 15% tax when you make money. For our club, we would not pay too often! You might save more in legal and accounting than you would save in tax.


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## Ken S. (Feb 2, 2005)

[I guess the easiest way around it would be to include A $5 membership surcharge to the entry fee (not to increase the entry fee, just classify $5 that way) so that every single person who runs in the trial / tests are considered associate members (The 35% rule says nothing about what type of membership, just membership). So if you would do this, it would mean that everyone who runs in the trial/test are considered members of some sort, so all entry fees for them would be considered member receipts.[/QUOTE]

This will also work.


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## Zman1001 (Oct 15, 2009)

captainjack said:


> I believe the intent of the 35% is from member dues not member test fees but none the less, the everyone is a member idea won't fly.
> 
> The 35% is only one of the criteria..
> 
> ...



See, now this is where intent and written are always confused. I do not know what the intent was, but it says nothing about member sources. It says:

"social club may receive up to 35 percent of its gross receipts from nonmember sources, including investment income"

I see the issues that are out there with these crazy IRS rules, especially when it comes to the clubs out there. We all want to comply, but it seems the IRS is making it hard for us to do that.

The clubs are not out to make a profit year to year just to make a profit. The clubs are out there to further the sport, provide education to its members (either through training days or seminars that are held) and provide fellowship amongst the members (either through training days, or trials / tests).


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## Eric Johnson (Dec 23, 2004)

I would bet that the vast majority of dog club which are incorporated as non-profits are designated as 501(c)7. Probably a lot of clubs aren't even incorporated at all but those that are and that file for a non-profit status....are 501(c)7.

Glen, the example of a flying club isn't particularly definitive because of the differences between dog clubs and the example flying club.

As I've said, any club that wishes to file for 501(c)3 status, have at it. Please report back. Historically, a filing for 501(c)3 status is not successful for dog clubs. Been there. Done that.

Eric


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## captainjack (Apr 6, 2009)

Zman1001 said:


> See, now this is where intent and written are always confused. I do not know what the intent was, but it says nothing about member sources. It says:
> 
> "social club may receive up to 35 percent of its gross receipts from nonmember sources, including investment income"
> 
> ...


If you think the IRS code is big & confusing, take a look at the treasury regulations that explain/interpret the code.

I really believe that the 501c7 is not the right way to go and think that those clubs organized under that section are no more in compliance with IRS regulations than a club that hasn't filed for exemption under any section. But that's just my opinion. There may be some revenue ruling or other guidance not in the Code. 

I think the 501c3 is the way. I've seen various non-profits organized as 501c3 and meet the "education" purpose by holding seminars, clinics, shows, etc...

Some have unrealated business income and some don't.

Since most clubs pretty much try to break-even on tests, another option might be to form two separate organizations, one a 501c7 and one a regular C corp. The C corp could hold the tests which will pretty much be a break-even deal with no profit and thus no tax. The 501c7 could receive 35% of its gross receipts from sources other than club members. So a club with 100 members paying $25 annual dues could receive about $1,350 a year from "other sources".

I'll end up doing the research on this deal and figure out how it should be done.


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## captainjack (Apr 6, 2009)

Eric Johnson said:


> ...
> 
> Glen, the example of a flying club isn't particularly definitive because of the differences between dog clubs and the example flying club.
> 
> ...


The example is very definitive.

"An essential earmark of an exempt social club is personal contact, commingling, and face-to-face fellowship."

It makes no difference if we are talking dogs or airplanes, coming to a hunt test or a fly in once a year with people you don't know doesn't pass muster IMO.


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## firehouselabs (Jan 23, 2008)

captainjack said:


> From the IRS...
> "Social Clubs – Requirements for Exemption – Support By Membership Dues
> 
> A social club must be supported by membership fees, dues, and assessments. *A section 501(c)(7) organization may receive up to 35 percent of its gross receipts, including investment income, from sources outside of its membership without losing its tax-exempt status. *No more than 15 percent of the this amount may be derived form use of the club’s facilities or services by the general public or from other activities not furthering social or recreational purposes for members. If an organization has non-member income exceeding these limits, all the facts and circumstances will be considered in determining whether the club continues to qualify for exemption ."
> ...



What about this line? Any income generated from entry fees, raffles, fund raisers, etc... DO go to further recreational and social purposes for its members. These funds buy equipment, lease land and club houses, help pay for fun activities, seminars, and public awareness, plus training days. All of these are recreational and social in nature. The only time it is NOT is if one lonely Pro is out on the grounds training by himself and using the land, equipment, etc.. for profit, not enjoyment (which if you do not enjoy training dogs, you really shouldn't be training dogs!). Even then that person(s) can "use" up to 15% of of the 35% allowed, correct?
Heck, I always have lots of fun (recreational) and social interaction at ever test I run. Of course I do not run these tests "professionally", as in getting paid to, but even if I did the social aspect still comes into play and very few of us can say that we have made money by *playing dog games? *


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## Eric Johnson (Dec 23, 2004)

Glen - 

When we applied for 501(c) status, the IRS agreed that 501(c)(7) was the correct one. They were very clear that we didn't fit 501(c)(3) because 501(c)(3) is both non-profit and tax-exempt and the donations to it are tax deductible. 

IRS Publication 557 says WRT a 501(c)(3) 

"An organization may qualify for exemption from federal income tax if it is organized and operated exclusively for one or more of the following purposes.

Religious.
Charitable. 
Scientific. 
Testing for public safety.
Literary.
Educational. 
Fostering national or international amateur sports competition (but only if none of its activities involve providing athletic facilities or equipment; however, see Amateur Athletic Organizations, later in this chapter).
The prevention of cruelty to children or animals." (page 19)

I would venture a guess that the words "exclusively" along with the laundry list is the principle reason why a retriever clubs today are not able to achieve this status.

Later it says WRT 501(c)(7) organizations, "Typical organizations that should file for recognition of exemption as social clubs include:

1.
2.
3.
4. Amateur hunting, fishing, tennis, swimming, and other sport clubs,
5.
6.
7." (page 48)

A flying club is not like a retriever club because of the human interaction. The flying club existed principally (solely ?) to pool capital to buy an airplane which members "time-share." There is little or no human interaction, read club, involved in flying a plane. Been there, done that too.

As I've indicated, I've been through this whole painful process. The IRS said we were a 501(c)(7) organization. If you have made a successful case for 501(c)(3) status to the IRS, I'd be interested to learn from it. If however, you are merely conjecturing without the benefit of actual experience, we'll have to leave it at that. 

Eric


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## captainjack (Apr 6, 2009)

Eric Johnson said:


> ...
> 
> As I've indicated, I've been through this whole painful process. The IRS said we were a 501(c)(7) organization. If you have made a successful case for 501(c)(3) status to the IRS, I'd be interested to learn from it. If however, you are merely conjecturing without the benefit of actual experience, we'll have to leave it at that.
> 
> Eric


There is more than one retriever club organized as a 501c3, so I know for a fact that it can be done. The fact that I haven't done it myself only means exactly that, I haven't done it myself. It doesn't mean that it is not possible or that it is not correct.

Regardless of the IRS saying you were a 501c7 (which I'd assume was based on the information that you put on your application), I still don't see how your club can hold tests or trials and be in compliance with the IRS rules for a 501c7. If your club is in compliance, I'd be interested to learn from it. If however, you are merely conjecturing without the benefit of actual knowledge of your club's compliance, we'll have to leave it at that.


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## Ken S. (Feb 2, 2005)

There are quite a number of clubs, field and bench, that have 501(c)(3) status, as I stated before. Way too many to count (easily). Also, all conservation organizations are 501(c)(3). The purpose being to promote the breeds, sport, etc. will meet if done correctly. Finding good counsel who can walk you through the process is important.


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## Eric Johnson (Dec 23, 2004)

We are a slightly different club. We are a breed club, not an all breed performance club. As a result, we hoild more than field trials and/or hunt tests. We hold conformation shows, agility and obedience trials, as well as hunt tests. In addition we support rescue and breed health programs.

I was Treasurer for 9 years. During that time we incorporated and filed for 501(c)(7) status. By the time I completed my years in office in 2005, we had roughly $45K in annual income from various sources. We were very careful to stay on the right side of the IRS by reporting unrelated business income which included income from non-members.

There are about 3 clubs that made it under the ropes to achieve 501(c)(3) status on the "educational" basis. Blackhawk and one of the Alaskan clubs are two that I know of from my research way back when. It's been cited here that these clubs do a significant amount of non-traditional stuff to maintain that 501(c)(3). I assume that these clubs file 990's or 990EZ. If so, the IRS watches them and re-confirms from time to time the 501(c)(3) status. If they don't file 990 or 990EZ, then there's nothing to talk about.

When I was researching this for the club, I was told by the IRS that a dog club could not achieve 501(c)(3) status today except in very unusual circumstances. I asked how clubs had done so in the past and was told "not any more." The attorney I had help with the application reviewed about 5 years of IRS findings. It just wasn't there. So, the three clubs represent an anomoly rather than the norm. I did confirm with IRS that we could have a separate entity that was 501(c)(3) for the purposes of supporting the health and rescue programs. There were some fairly rigid requirements governing the relationship between the club .... 501(c)(7)....and the "foundation" ...501(C)(3). We never pursued the foundation structure.

So...I've done it and I made certain we comply. The current Treasurer is with an accounting firm in Milwaukee that specializes in non-profit organizations. I feel confident that she keeps us in compliance as well.

I don't know how to make it any more clear. I've gone through the process and for 8 years we filed with the IRS and got no grief....nary a question from them. 

Have you looked at Publication 557?

Eric


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## Ken S. (Feb 2, 2005)

Yes, and being someone in the profession I have quite a bit of experience in this area. Many more years and with numerous clients. While your club (or any other) may be different, it is possible, and not hard. That someone "spoke" with someone at the IRS means little, as even practitioners do not get someone who speaks with authority in a general call about an issue. They do have conventions they follow, and their goal is to generally discourage anyone from getting charitable status unless it is clear. My point is it is very doable and should not be discouraged versus a c7 which has its limitations. That is a disservice to someone whose situation may work. The skilled attorney will know the ropes, as much of the process revolves around the legal work.


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## Eric Johnson (Dec 23, 2004)

Ken-

We had a very skilled attorney. He looked at the last five years worth of decisions by IRS to come to a conclusion. Do you know of a specific club that did this within the last ten years? I'm willing to learn but need to see a winning hand.

Eric


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## Ken S. (Feb 2, 2005)

I don't know personally but will talk with some people I know and see. I am not in public practice any more so I as involved as I used to be, but have never had a client get refused if done correctly. A lot if it is form over substance, which is why all the original drafting is important. I do think that the C7 gross revenue is a problem, but there are solutions to that which have been mentioned here.


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