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Colorful clay figures of a police man and business man with a bag of money

Cooperative fundraising / IFAs

"Cooperative fundraising" is when a group's members join together (cooperatively) to raise money and then credit the funds raised (or the time spent volunteering) to the individuals who participated in raising the money (the accounts credited are known as "Individual fundraising accounts"). These types of activities, while common among booster clubs, are not considered a 501(c)(3) tax-exempt activity.

Tax-exempt 501(c)(3) organizations must be operated for a "public" purpose. Booster clubs, for example, often operate for public purposes such as supporting amateur athletics, supporting arts in the schools, community support for public education and the like. The IRS and tax court have both found that cooperative fundraising activities are operated for the private benefit of the individual members of the group involved in the fundraising. This type of cooperative fundraising may be engaged in by a for-profit, tax-paying organization, but not by a nonprofit, tax-exempt 501(c)(3) group. If cooperative fundraising comprises any significant part of your group's total activities (think more than 5% of total funds raised are credited to the individual accounts of parents/students participating in the fundraising although the IRS does not have a specific percentage test), then your group likely would not be considered to qualify for 501(c)(3) status by the IRS.

PBUSA highly recommends avoiding the use of Cooperative Fundraising or Individual Fundraising Accounts entirely. See the PBUSA IFA Policy. Other fundraising options include:

  • Fair share donation plans -- in which your organization advises parents/students of the cost of participating and encourages, but does not require, that contributions of a set amount be paid
  • Seeking out corporate, foundation and other donations, letting the donors know that contributions are tax-deductible provided nothing of significant value is received for the donation
  • Using all funds raised to support the entire group, regardless of volunteer or fundraising participation
Related articles

IRS Article - Athletic Booster Clubs: Are They Exempt?

Tax Court Ruling - Capital Gymnastics: August 2013

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