It's not just the action itself, it's the action as it relates to the
organization. Here's the relevant part from the IRS:

   1. For most organizations, an activity is an *unrelated business* (and
   subject to *unrelated business income* tax) if it meets three
   requirements: It is a trade or *business*, It is regularly carried on,
   and. It is not substantially related to furthering the exempt purpose of
   the organization.

I suspect that we could argue that it is, in fact, related to furthering
the exempt purpose of the organization, but there's a significant chance
that the IRS wouldn't see it this way, and I don't see the need to risk it.
But IANAL. We'll have one on retainer for these kinds of questions as we go
through the formation, if that ends up happening.

--Matt



On Thu, Jul 31, 2014 at 9:40 PM, Doug Hughes <[email protected]> wrote:

> On 7/31/2014 9:13 PM, Matt Simmons wrote:
>
>>
>> It was decided after LOPSA-East of this year that PICC should shut down
>> for reasons personal to PICC management. Since LOPSA local chapters
>> aren't incorporated (or at least, these aren't), it's unrealistic to
>> expect individual members of the community to assume a financial risk of
>> tens of thousands of dollars to organize a conference, so when
>> evaluating what could be done, the idea was raised to have LOPSA itself
>> be responsible for its own conferences, entirely. Still, the financial
>> risk is immense. LOPSA-East costs between $60,000 and $70,000 to put on,
>> and that's double what LOPSA has in the bank. Not to mention that it's
>> very likely to be considered "unrelated business income", and thus it
>> could put LOPSA's 501c3 status in jeopardy.
>>
>>  Very likely? I find that surprising. We have an existence proof of the
> opposite by way of Usenix with its various conferences. Why do you think
> this is very likely when Usenix has been running conferences to fund other
> initiatives for many years? How, also, could it be considered unrelated
> since it is part of the core charter of LOPSA to provide education of one
> form or another?
>
> I don't dispute the financial risk at all, fwiw.
>
>
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