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71-715: The Boston Harbor Islands Partnership is a non-profit partnership organization based in Boston , whose purpose is "to coordinate the activities of the Federal, State, and local authorities and the private sector in the development and implementation of a general management plan" for the Boston Harbor Islands National Recreation Area . The Partnership was established by the United States Congress in 1996, as part of

142-471: A safe harbor for the "substantial part" test, the United States Congress enacted §501(h), called the Conable election after its author, Representative Barber Conable . The section establishes limits based on operating budget that a charity can use to determine if it meets the substantial test. This changes the prohibition against direct intervention in partisan contests only for lobbying. The organization

213-687: A business aiming to generate a profit for its owners. A nonprofit organization is subject to the non-distribution constraint: any revenues that exceed expenses must be committed to the organization's purpose, not taken by private parties. Depending on the local laws, charities are regularly organized as non-profits. A host of organizations may be nonprofit, including some political organizations, schools, hospitals, business associations, churches, foundations, social clubs, and consumer cooperatives. Nonprofit entities may seek approval from governments to be tax-exempt , and some may also qualify to receive tax-deductible contributions, but an entity may incorporate as

284-509: A candidate in some manner, or (c) favor a candidate or group of candidates, constitute prohibited participation or intervention. Since section 501(c)(3)'s political-activity prohibition was enacted, "commentators and litigants have challenged the provision on numerous constitutional grounds", such as freedom of speech , vagueness , and equal protection and selective prosecution. Historically, Supreme Court decisions, such as Regan v. Taxation with Representation of Washington , suggested that

355-595: A choice between two sets of rules establishing an upper bound for their lobbying activities. Section 501(c)(3) organizations risk loss of their tax-exempt status if these rules are violated. An organization that loses its 501(c)(3) status due to being engaged in political activities cannot subsequently qualify for 501(c)(3) status. Churches must meet specific requirements to obtain and maintain tax-exempt status; these are outlined in "IRS Publication 1828: Tax Guide for Churches and Religious Organizations". This guide outlines activities allowed and not allowed by churches under

426-544: A church's principal means of accomplishing its religious purposes must be to assemble regularly a group of individuals related by common worship and faith." The United States Tax Court has stated that, while a church can certainly broadcast its religious services by radio, radio broadcasts themselves do not constitute a congregation unless there is a group of people physically attending those religious services. A church can conduct worship services in various specific locations rather than in one official location. A church may have

497-424: A delegate structure to allow for the representation of groups or corporations as members. Alternatively, it may be a non-membership organization and the board of directors may elect its own successors. The two major types of nonprofit organization are membership and board-only. A membership organization elects the board and has regular meetings and the power to amend the bylaws. A board-only organization typically has

568-554: A fiscally viable entity. Nonprofits have the responsibility of focusing on being professional and financially responsible, replacing self-interest and profit motive with mission motive. Though nonprofits are managed differently from for-profit businesses, they have felt pressure to be more businesslike. To combat private and public business growth in the public service industry, nonprofits have modeled their business management and mission, shifting their reason of existing to establish sustainability and growth. Setting effective missions

639-411: A foreign subsidiary to facilitate charitable work in a foreign country, then donors' contributions to the 501(c)(3) organization are tax-deductible even if intended to fund the foreign charitable activities. If a foreign organization sets up a 501(c)(3) organization for the sole purpose of raising funds for the foreign organization, and the 501(c)(3) organization sends substantially all contributions to

710-444: A limited amount of lobbying to influence legislation. Although the law states that "no substantial part" of a public charity's activities can go to lobbying, charities with large budgets may lawfully expend a million dollars (under the "expenditure" test) or more (under the "substantial part" test) per year on lobbying. The Internal Revenue Service has never defined the term "substantial part" with respect to lobbying. To establish

781-471: A low-stress work environment that the employee can associate him or herself positively with. Other incentives that should be implemented are generous vacation allowances or flexible work hours. When selecting a domain name , NPOs often use one of the following: .org , the country code top-level domain of their respective country, or the .edu top-level domain (TLD), to differentiate themselves from more commercial entities, which typically use .com . In

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852-783: A manner consistent with a particular religion's religious beliefs does not qualify as a tax-exempt church. Organizations described in section 501(c)(3) are prohibited from conducting political campaign activities to intervene in elections to public office. The Internal Revenue Service website elaborates on this prohibition: Under the Internal Revenue Code, all section 501(c)(3) organizations are absolutely prohibited from directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any candidate for elective public office. Contributions to political campaign funds or public statements of position (verbal or written) made on behalf of

923-467: A non-partisan manner do not constitute prohibited political campaign activity. In addition, other activities intended to encourage people to participate in the electoral process, such as voter registration and get-out-the-vote drives, would not be prohibited political campaign activity if conducted in a non-partisan manner. On the other hand, voter education or registration activities with evidence of bias that (a) favor one candidate over another, (b) oppose

994-457: A nonprofit entity without having tax-exempt status. Key aspects of nonprofits are accountability, integrity, trustworthiness, honesty, and openness to every person who has invested time, money, and faith into the organisation. Nonprofit organizations are accountable to the donors, founders, volunteers, program recipients, and the public community. Theoretically, for a nonprofit that seeks to finance its operations through donations, public confidence

1065-697: A self-selected board and a membership whose powers are limited to those delegated to it by the board. A board-only organization's bylaws may even state that the organization does not have any membership, although the organization's literature may refer to its donors or service recipients as 'members'; examples of such organizations are FairVote and the National Organization for the Reform of Marijuana Laws . The Model Nonprofit Corporation Act imposes many complexities and requirements on membership decision-making. Accordingly, many organizations, such as

1136-442: A significant number of people associate themselves with the church on a regular basis, even if the church does not have a traditional established list of individual members. In order to qualify as a tax-exempt church, church activities must be a significant part of the organization's operations. An organization whose operations include a substantial nonexempt commercial purposes, such as operating restaurants and grocery stores in

1207-423: A significant portion of a church school's curriculum is religious education. For a payment to be a tax-deductible charitable contribution, it must be a voluntary transfer of money or other property with no expectation of procuring financial benefit equal to the transfer amount. Before donating to a 501(c)(3) organization, a donor can consult the searchable online IRS list of charitable organizations to verify that

1278-471: A strong vision of how to operate the project, try to retain control of the organization, even as new employees or volunteers want to expand the project's scope or change policy. Resource mismanagement is a particular problem with NPOs because the employees are not accountable to anyone who has a direct stake in the organization. For example, an employee may start a new program without disclosing its complete liabilities. The employee may be rewarded for improving

1349-432: A tax deduction on a charitable gift to a 501(c)(3) organization that is organized and operated exclusively for religious, charitable, scientific, literary or educational purposes, or to foster national or international amateur sports competition (but only if no part of its activities involve the provision of athletic facilities or equipment), or for the prevention of cruelty to children or animals. An individual may not take

1420-440: A tax deduction on gifts made to a 501(c)(3) organization that is organized and operated exclusively for the testing for public safety. In the case of tuition fees paid to a private 501(c)(3) school or a church school, the payments are not tax-deductible charitable contributions because they are payments for services rendered to the payee or the payee's children. The payments are not tax-deductible charitable contributions even if

1491-581: A wide diversity of structures and purposes. For legal classification, there are, nevertheless, some elements of importance: Some of the above must be (in most jurisdictions in the US at least) expressed in the organization's charter of establishment or constitution. Others may be provided by the supervising authority at each particular jurisdiction. While affiliations will not affect a legal status, they may be taken into consideration by legal proceedings as an indication of purpose. Most countries have laws that regulate

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1562-399: Is a factor in the amount of money that a nonprofit organization is able to raise. Supposedly, the more a nonprofit focuses on their mission, the more public confidence they will gain. This will result in more money for the organization. The activities a nonprofit is partaking in can help build the public's confidence in nonprofits, as well as how ethical the standards and practices are. There

1633-461: Is a key for the successful management of nonprofit organizations. There are three important conditions for effective mission: opportunity, competence, and commitment. One way of managing the sustainability of nonprofit organizations is to establish strong relations with donor groups. This requires a donor marketing strategy, something many nonprofits lack. Nonprofit organizations provide public goods that are undersupplied by government. NPOs have

1704-557: Is a searchable database of information about organizations over time. WikiCharities, is a nonprofit database of nonprofits and charities by name, location, and topic, that allows each organization to report its financials, leadership, contacts, and other activities. Section 501(c)(3) organizations are prohibited from supporting political candidates, as a result of the Johnson Amendment enacted in 1954. Section 501(c)(3) organizations are subject to limits on lobbying , having

1775-434: Is allowed to award grants to foreign charitable organizations if the grants are intended for charitable purposes and the grant funds are subject to the 501(c)(3) organization's control. Additional procedures are required of 501(c)(3) organizations that are private foundations . Donors' contributions to a 501(c)(3) organization are tax-deductible only if the contribution is for the use of the 501(c)(3) organization, and that

1846-800: Is an actual controversy regarding a determination or the Internal Revenue Service has failed to make a determination. In these cases, the United States Tax Court , the United States District Court for the District of Columbia , and the United States Court of Federal Claims have concurrent jurisdiction to issue a declaratory judgment of the organization's qualification if the organization has exhausted administrative remedies with

1917-439: Is an important distinction in the US between non-profit and not-for-profit organizations (NFPOs); while an NFPO does not profit its owners, and money goes into running the organization, it is not required to operate for the public good. An example is a club, whose purpose is its members' enjoyment. Other examples of NFPOs include: credit unions, sports clubs, and advocacy groups. Nonprofit organizations provide services to

1988-414: Is an important distinction in the US between non-profit and not-for-profit organizations (NFPOs); while an NFPO does not profit its owners, and money goes into running the organization, it is not required to operate for the public good. An example is a sports club, whose purpose is its members' enjoyment. The names used and precise regulations vary from one jurisdiction to another. According to

2059-557: Is concerned. In many countries, nonprofits may apply for tax-exempt status, so that the organization itself may be exempt from income tax and other taxes. In the United States, to be exempt from federal income taxes, the organization must meet the requirements set forth in the Internal Revenue Code (IRC). Granting nonprofit status is done by the state, while granting tax-exempt designation (such as IRC 501(c) )

2130-453: Is granted by the federal government via the IRS. This means that not all nonprofits are eligible to be tax-exempt. For example, employees of non-profit organizations pay taxes from their salaries, which they receive according to the laws of the country. NPOs use the model of a double bottom line in that furthering their cause is more important than making a profit, though both are needed to ensure

2201-408: Is not classifiable as another category. Currently, no restrictions are enforced on registration of .com or .org, so one can find organizations of all sorts in either of those domains, as well as other top-level domains including newer, more specific ones which may apply to particular sorts of organization including .museum for museums and .coop for cooperatives . Organizations might also register by

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2272-478: Is not required to be made available to the public, unless the organization is an independent foundation. Churches are generally exempt from this reporting requirement. Every 501(c)(2) organization must make available for public inspection its application for tax-exemption, including its Form 1023 or Form 1023-EZ and any attachments, supporting documents, and follow-up correspondence with the Internal Revenue Service. The same public inspection requirement applies to

2343-443: Is now presumed in compliance with the substantiality test if they work within the limits. The Conable election requires a charity to file a declaration with the IRS and file a functional distribution of funds spreadsheet with their Form 990. IRS form 5768 is required to make the Conable election. A 501(c)(3) organization is allowed to conduct some or all of its charitable activities outside the United States. A 501(c)(3) organization

2414-406: Is reduced to $ 400. There are some classes of organizations that automatically are treated as tax exempt under 501(c)(3), without the need to file Form 1023: The IRS released a software tool called Cyber Assistant in 2013, which was succeeded by Form 1023-EZ in 2014. There is an alternative way for an organization to obtain status if an organization has applied for a determination and either there

2485-467: Is that the organization is specifically limited in powers to purposes that the IRS classifies as tax-exempt purposes. Unlike for-profit corporations that benefit from broad and general purposes, non-profit organizations need to be limited in powers to function with tax-exempt status, but a non-profit corporation is by default not limited in powers until it specifically limits itself in the articles of incorporation or nonprofit corporate bylaws. This limiting of

2556-411: Is the remuneration package, though many who have been questioned after leaving an NPO have reported that it was stressful work environments and the workload. Public- and private-sector employment have, for the most part, been able to offer more to their employees than most nonprofit agencies throughout history. Either in the form of higher wages, more comprehensive benefit packages, or less tedious work,

2627-476: Is unique in which source of income works best for them. With an increase in NPOs since 2010, organizations have adopted competitive advantages to create revenue for themselves to remain financially stable. Donations from private individuals or organizations can change each year and government grants have diminished. With changes in funding from year to year, many nonprofit organizations have been moving toward increasing

2698-729: The National Center for Charitable Statistics (NCCS), there are more than 1.5 million nonprofit organizations registered in the United States , including public charities , private foundations , and other nonprofit organizations. Private charitable contributions increased for the fourth consecutive year in 2017 (since 2014), at an estimated $ 410.02 billion. Out of these contributions, religious organizations received 30.9%, education organizations received 14.3%, and human services organizations received 12.1%. Between September 2010 and September 2014, approximately 25.3% of Americans over

2769-596: The Wikimedia Foundation , have formed board-only structures. The National Association of Parliamentarians has generated concerns about the implications of this trend for the future of openness, accountability, and understanding of public concerns in nonprofit organizations. Specifically, they note that nonprofit organizations, unlike business corporations, are not subject to market discipline for products and shareholder discipline of their capital; therefore, without membership control of major decisions such as

2840-434: The 14-point list is a guideline; it is not intended to be all-encompassing, and other facts and circumstances may be relevant factors. Although there is no definitive definition of a church for Internal Revenue Code purposes, in 1986 the United States Tax Court said that "A church is a coherent group of individuals and families that join together to accomplish the religious purposes of mutually held beliefs. In other words,

2911-502: The 501(c)(3) designation. In 1980, the United States District Court for the District of Columbia recognized a 14-part test in determining whether a religious organization is considered a church for the purposes of the Internal Revenue Code: Having an established congregation served by an organized ministry is of central importance. Points 4, 6, 8, 11, 12, and 13 are also especially important. Nevertheless,

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2982-405: The 501(c)(3) organization is not merely serving as an agent or conduit of a foreign charitable organization. The 501(c)(3) organization's management should review the grant application from the foreign organization, decide whether to award the grant based on the intended use of the funds, and require continuous oversight based on the use of funds. If the donor imposes a restriction or earmark that

3053-548: The Court, if it were to squarely examine the political-activity prohibition of § 501(c)(3), would uphold it against a constitutional challenge. However, some have suggested that a successful challenge to the political activities prohibition of Section 501(c)(3) might be more plausible in light of Citizens United v. FEC . In contrast to the prohibition on political campaign interventions by all section 501(c)(3) organizations, public charities (but not private foundations) may conduct

3124-432: The Internal Revenue Service. Prior to October 9, 1969, nonprofit organizations could declare themselves to be tax-exempt under Section 501(c)(3) without first obtaining Internal Revenue Service recognition by filing Form 1023 and receiving a determination letter. A nonprofit organization that did so prior to that date could still be subject to challenge of its status by the Internal Revenue Service. Individuals may take

3195-455: The NPO's reputation, making other employees happy, and attracting new donors. Liabilities promised on the full faith and credit of the organization but not recorded anywhere constitute accounting fraud . But even indirect liabilities negatively affect the financial sustainability of the NPO, and the NPO will have financial problems unless strict controls are instated. Some commenters have argued that

3266-461: The age of 16 volunteered for a nonprofit. In the United States, both nonprofit organizations and not-for-profit organizations are tax-exempt. There are various types of nonprofit exemptions, such as 501(c)(3) organizations that are a religious, charitable, or educational-based organization that does not influence state and federal legislation, and 501(c)(7) organizations that are for pleasure, recreation, or another nonprofit purpose. There

3337-649: The appropriate country code top-level domain for their country. In 2020, nonprofit organizations began using microvlogging (brief videos with short text formats) on TikTok to reach Gen Z, engage with community stakeholders, and overall build community. TikTok allowed for innovative engagement between nonprofit organizations and younger generations. During COVID-19, TikTok was specifically used to connect rather than inform or fundraise, as its fast-paced, tailored For You Page separates itself from other social media apps such as Facebook and Twitter. Some organizations offer new, positive-sounding alternative terminology to describe

3408-401: The best of the newly minted workforce. It has been mentioned that most nonprofits will never be able to match the pay of the private sector and therefore should focus their attention on benefits packages, incentives and implementing pleasurable work environments. A good environment is ranked higher than salary and pressure of work. NPOs are encouraged to pay as much as they are able and offer

3479-565: The community; for example aid and development programs, medical research, education, and health services. It is possible for a nonprofit to be both member-serving and community-serving. Nonprofit organizations are not driven by generating profit, but they must bring in enough income to pursue their social goals. Nonprofits are able to raise money in different ways. This includes income from donations from individual donors or foundations; sponsorship from corporations; government funding; programs, services or merchandise sales, and investments. Each NPO

3550-405: The contribution must be used for foreign activities, then the contribution is deemed to be for the foreign organization rather than the 501(c)(3) organization, and the contribution is not tax-deductible. The purpose of the grant to the foreign organization cannot include endorsing or opposing political candidates for elected office in any country. If a 501(c)(3) organization sets up and controls

3621-402: The diversity of their funding sources. For example, many nonprofits that have relied on government grants have started fundraising efforts to appeal to individual donors. Most nonprofits have staff that work for the company, possibly using volunteers to perform the nonprofit's services under the direction of the paid staff. Nonprofits must be careful to balance the salaries paid to staff against

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3692-432: The election of the board, there are few inherent safeguards against abuse. A rebuttal to this might be that as nonprofit organizations grow and seek larger donations, the degree of scrutiny increases, including expectations of audited financial statements. A further rebuttal might be that NPOs are constrained, by their choice of legal structure, from financial benefit as far as distribution of profit to members and directors

3763-475: The establishment and management of NPOs and that require compliance with corporate governance regimes. Most larger organizations are required to publish their financial reports detailing their income and expenditure publicly. In many aspects, they are similar to corporate business entities though there are often significant differences. Both not-for-profit and for-profit corporate entities must have board members, steering-committee members, or trustees who owe

3834-803: The law which designated the Boston Harbor Islands as a unit of the national parks system. Members of the Boston Harbor Islands Partnership often work closely with other Harbor-affiliated organizations (both non-profits and for-profits) that are not themselves members of the Partnership. The Island Alliance, the Department of Conservation and Recreation, and the National Park Service made a joint decision to select Eastern National to manage

3905-511: The money paid to provide services to the nonprofit's beneficiaries. Organizations whose salary expenses are too high relative to their program expenses may face regulatory scrutiny. A second misconception is that nonprofit organizations may not make a profit. Although the goal of nonprofits is not specifically to maximize profits, they still have to operate as a fiscally responsible business. They must manage their income (both grants and donations and income from services) and expenses so as to remain

3976-445: The nonprofit sector today regarding newly graduated workers, and to some, NPOs have for too long relegated hiring to a secondary priority, which could be why they find themselves in the position many do. While many established NPOs are well-funded and comparative to their public sector competitors, many more are independent and must be creative with which incentives they use to attract and maintain people. The initial interest for many

4047-411: The organization a fiduciary duty of loyalty and trust. A notable exception to this involves churches , which are often not required to disclose finances to anyone, including church members. In the United States, nonprofit organizations are formed by filing bylaws, articles of incorporation , or both in the state in which they expect to operate. The act of incorporation creates a legal entity enabling

4118-515: The organization in favor of or in opposition to any candidate for public office clearly violate the prohibition against political campaign activity. Violating this prohibition may result in denial or revocation of tax-exempt status and the imposition of certain excise taxes. Certain activities or expenditures may not be prohibited depending on the facts and circumstances. For example, certain voter education activities (including presenting public forums and publishing voter education guides) conducted in

4189-435: The organization qualifies to receive tax-deductible charitable contributions. Consumers may file IRS Form 13909, with documentation, to complain about inappropriate or fraudulent (i.e., fundraising, political campaigning, lobbying) activities by any 501(c)(3) organization. Most 501(c)(3) must disclose the names and addresses of certain large donors to the Internal Revenue Service on their annual returns, but this information

4260-452: The organization to be treated as a distinct body (corporation) by law and to enter into business dealings, form contracts, and own property as individuals or for-profit corporations can. Nonprofits can have members, but many do not. The nonprofit may also be a trust or association of members. The organization may be controlled by its members who elect the board of directors , board of governors or board of trustees . A nonprofit may have

4331-840: The organization's annual return, namely its Form 990 , Form 990-EZ, Form 990-PF, Form 990-T, and Form 1065, including any attachments, supporting documents, and follow-up correspondence with the Internal Revenue Service, with the exception of the names and addresses of donors on Schedule B. Annual returns must be publicly available for a three-year period beginning with the due date of the return, including any extension of time for filing. The Internal Revenue Service provides information about specific 501(c)(3) organizations through its Tax Exempt Organization Search online. A private nonprofit organization, GuideStar , provides information on 501(c)(3) organizations. ProPublica's Nonprofit Explorer provides copies of each organization's Form 990 and, for some organizations, audited financial statements. Open990

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4402-511: The organization's sustainability. An advantage of nonprofits registered in the UK is that they benefit from some reliefs and exemptions. Charities and nonprofits are exempt from Corporation Tax as well as the trustees being exempt from Income Tax. There may also be tax relief available for charitable giving, via Gift Aid, monetary donations, and legacies. Founder's syndrome is an issue organizations experience as they expand. Dynamic founders, who have

4473-556: The park bookstore located in the Visitors' Center on Georges Island as well as the retail location at the Boston Harbor Islands Pavilion . Non-profit A nonprofit organization ( NPO ), also known as a nonbusiness entity , nonprofit institution , or simply a nonprofit , is a legal entity organized and operated for a collective, public or social benefit, as opposed to an entity that operates as

4544-409: The powers is crucial to obtaining tax exempt status with the IRS and then on the state level. Organizations acquire 501(c)(3) tax exemption by filing IRS Form 1023 . As of 2006 , the form must be accompanied by an $ 850 filing fee if the yearly gross receipts for the organization are expected to average $ 10,000 or more. If yearly gross receipts are expected to average less than $ 10,000, the filing fee

4615-676: The prevention of cruelty to children or animals . 501(c)(3) exemption applies also for any non-incorporated community chest , fund, cooperating association or foundation organized and operated exclusively for those purposes. There are also supporting organizations—often referred to in shorthand form as "Friends of" organizations. 26 U.S.C.   § 170 provides a deduction for federal income tax purposes, for some donors who make charitable contributions to most types of 501(c)(3) organizations, among others. Regulations specify which such deductions must be verifiable to be allowed (e.g., receipts for donations of $ 250 or more). Due to

4686-550: The public and private sectors have enjoyed an advantage over NPOs in attracting employees. Traditionally, the NPO has attracted mission-driven individuals who want to assist their chosen cause. Compounding the issue is that some NPOs do not operate in a manner similar to most businesses, or only seasonally. This leads many young and driven employees to forego NPOs in favor of more stable employment. Today, however, nonprofit organizations are adopting methods used by their competitors and finding new means to retain their employees and attract

4757-483: The receipt of significant funding from large for-profit corporations can ultimately alter the NPO's functions. A frequent measure of an NPO's efficiency is its expense ratio (i.e. expenditures on things other than its programs, divided by its total expenditures). Competition for employees with the public and private sector is another problem that nonprofit organizations inevitably face, particularly for management positions. There are reports of major talent shortages in

4828-602: The sector in its own terms, without relying on terminology used for the government or business sectors. However, use of terminology by a nonprofit of self-descriptive language that is not legally compliant risks confusing the public about nonprofit abilities, capabilities, and limitations. 501(c)(3) organization 501(c)(3) tax-exemptions apply to entities that are organized and operated exclusively for religious , charitable , scientific , literary or educational purposes, for testing for public safety , to foster national or international amateur sports competition, or for

4899-570: The sector. The term civil society organization (CSO) has been used by a growing number of organizations, including the Center for the Study of Global Governance . The term citizen sector organization (CSO) has also been advocated to describe the sector – as one of citizens, for citizens – by organizations including Ashoka: Innovators for the Public . Advocates argue that these terms describe

4970-503: The tax deductions associated with donations, loss of 501(c)(3) status can be highly challenging if not fatal to a charity's continued operation, as many foundations and corporate matching funds do not grant funds to a charity without such status, and individual donors often do not donate to such a charity due to the unavailability of tax deduction for contributions. The two exempt classifications of 501(c)(3) organizations are as follows: The basic requirement of obtaining tax-exempt status

5041-489: The traditional domain noted in RFC   1591 , .org is for "organizations that didn't fit anywhere else" in the naming system, which implies that it is the proper category for non-commercial organizations if they are not governmental, educational, or one of the other types with a specific TLD. It is not designated specifically for charitable organizations or any specific organizational or tax-law status, but encompasses anything that

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