EllenAprill.bsky.social
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ellenaprill.bsky.social
EllenAprill.bsky.social
@ellenaprill.bsky.social
420 followers 390 following 88 posts
John E. Anderson Professor of Tax Law, Emerita LMU Loyola Law School; Senior Scholar in Residence, Lowell Milken Center for Philanthropy and Nonprofits, UCLA School of Law. My scholarly papers: https://papers.ssrn.com/sol3/results.cfm?RequestTimeout=500000
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ellenaprill.bsky.social
Those who care about this program, please read our comments explaining how the proposed regulations misapply this IRS doctrine. www.regulations.gov/comment/ED-2...
September 16, 2025 at 11:32 PM
ellenaprill.bsky.social
In National Religious Broadcasters v Commissioner of Internal Revenue, the parties have filed a Proposed Order. It woud enjoin the IRS from enforcing the Johnson Amendment against the two plaintiff churches. Many read the case more broadly. Here is my criticism of the proposal:
August 13, 2025 at 9:39 PM
ellenaprill.bsky.social
A proposed order in a pending case would enjoin enforcement of the Johnson Amendment against two plaintiff churches. This possible settlement, however, is being viewed as applying far more widely. This piece of mine evaluates its reasoning and impact: papers.ssrn.com/sol3/papers....
Misunderstanding National Religious Broadcasters
<div> <span>This piece examines the proposed order and joint motion for entry of consent judgment in National Religious Broadcasters v. Commissioner addressing
papers.ssrn.com
August 13, 2025 at 9:37 PM
Reposted by EllenAprill.bsky.social
jackjenkins.me
Of note: The Union for Reform Judaism is the largest Jewish denomination in the U.S.
jackjenkins.me Jack Jenkins @jackjenkins.me · Jul 28
INBOX: Union for Reform Judaism, Central Conference of American Rabbis & American Conference of Cantors issue a lengthy statement declaring:

"Starving Gazan civilians neither will bring Israel the 'total victory' over Hamas it seeks, nor can it be justified by Jewish values or humanitarian law."
Reform Jewish Movement Statement on Starvation in Gaza July 27, 2025 - The ongoing crisis in Gaza is a devastating reminder of the immense human cost of war. Nearly two years into Israel's war against Hamas, Israelis are still waiting for the return of their loved ones held hostage, and innocent Palestinians are caught in a mounting humanitarian catastrophe. Hamas has repeatedly demonstrated its willingness to sacrifice the Palestinian people in its pursuit of Israel's destruction, but Israel must not sacrifice its own moral standing in return. Neither escalating military pressure nor restricting humanitarian aid has brought Israel closer to securing a hostage deal or ending the war. While long-delayed and not-yet-certain to be more effective than previous efforts, we are encouraged by Saturday night's announcement that the Israeli military would revive the practice of dropping aid from airplanes and make it easier for aid convoys, including those from the UN's World Food Program, to move through Gaza along "designated humanitarian corridors," and to temporarily cease fighting in Gaza for a humanitarian pause. No one should be unaffected by the pervasive hunger experienced by thousands of Gazans. No one should spend the bulk of their time arguing technical definitions between starvation and pervasive hunger. The situation is dire, and it is deadly. Nor should we accept arguments that because Hamas is the primary reason many Gazans are either starving or on the verge of starving, that the Jewish State is not also culpable in this human disaster. The primary moral response must begin with anguished hearts in the face of such a large-scale human tragedy. Our tradition teaches that all people are created b tzelem Elohim — in the image of God. One consequence of this is the moral priority, which is affirmed throughout the Bible and rabbinic tradition, of feeding the hungry - both for the individual and for the self-governing Jewish community. More than a few members of t… Despite PM Netanyahu's calls to ignore these full members of his cabinet, their presence in this government has consistently morally compromised Israel's actions. Starving Gazan civilians neither will bring Israel the "total victory" over Hamas it seeks, nor can it be justified by Jewish values or humanitarian law. It's hard to imagine that this tragic approach will bring home the 50 remaining hostages, including the 20 who we pray are still alive. It's imperative that the Government of Israel ensures that the recently announced plans to deliver humanitarian aid succeed as Israel works with international partners to ensure its safe and sustained delivery and do whatever possible to reduce or eliminate the shootings and other injuries sustained at food distribution centers. We applaud Israel's green light for foreign nations to resume providing humanitarian aid to the Gaza population desperate for food and are confident that they will do all they can to ensure that such aid does not fall into the hands of Hamas. As Israel has effective control of 70% of Gaza, with the intent to remain in significant swaths of it, even if only temporarily, it should be directly involved, facilitate and cooperate with the international community, international humanitarian NGOs, and regional friends, to take urgently needed actions, such as these suggested by Israeli Reform rabbi and Member of Knesset Gilad Kariv: • To prevent the alarming number of civilian deaths in and around the food and humanitarian aid distribution sites. • Opening a significant number of food distribution centers at various locations across the Gaza Strip. • Large-scale entry of infant formula (especially liquid formula) and ensuring safe delivery to both functioning medical centers and the few remaining international aid facilities. • Establishing secure methods - potentially through cooperation with regional countries - for delivering food supplies to aid organizations and international agencies. • Resuming su… Finally, while it is imperative that Israel and the U.S. resume diplomacy to bring home all hostages and end this war, denying basic humanitarian aid crosses a moral line. Blocking food, water, medicine, and power- especially for children- is indefensible. Let us not allow our grief to harden into indifference, nor our love for Israel to blind us to the cries of the vulnerable. Let us rise to the moral challenge of this moment. Union for Reform Judaism Shelley Niceley Groff (she/her) North American Board Chair Rabbi Rick Jacobs (he/him) President Central Conference of American Rabbis Rabbi David A. Lyon (he/him) President Rabbi Hara Person (she/her) Chief Executive Officer American Conference of Cantors Cantor Josh Breitzer (he/him) President Rachel Roth (she/her) Chief Operating Officer
July 28, 2025 at 2:05 AM
ellenaprill.bsky.social
Any final order in the Texas the Johnson Amendment case would limit the IRS only re the two plaintiff churches. The proposed order, however, is being read broadly. This piece on the NY mayor’s race demonstrates vividly the pernicious effect of any change in the rule. www.nytimes.com/2025/07/17/n...
Faith Leaders Can Now Endorse. Will That Swing the N.Y.C. Mayor’s Race?
www.nytimes.com
July 20, 2025 at 6:36 PM
Reposted by EllenAprill.bsky.social
thebradblog.bsky.social
Trump IRS Agrees to Allow Churches to Endorse Candidates, Are All Nonprofits Next?: Today's #BradCast

Guest: Tax law Prof. @ellenaprill.bsky.social; Also: AZ special House primary; Inflation up as tariffs sink in; Tax dodge specialist writing tax policy...

FULL STORY, LISTEN: bradblog.com?p=15442
July 16, 2025 at 1:59 AM
Reposted by EllenAprill.bsky.social
rickhasen.bsky.social
Trump Administration Wants to Enter into a Consent Decree that Would Allow Churches and Other Religious Organizations to Get More Directly Involved in Electoral Politics Despite the “Johnson Amendment” electionlawblog.org?p=150800
Trump Administration Wants to Enter into a Consent Decree that Would Allow Churches and Other Religious Organizations to Get More Directly Involved in Electoral Politics Despite the "Johnson Amendment...
In the lawsuit raising constitutional objections to limits on religious nonprofits being involved in endorsing candidates and doing other election related activities, a proposed joint consent decree, ...
electionlawblog.org
July 7, 2025 at 10:32 PM
ellenaprill.bsky.social
Because my new piece, "Revocation of Exemption for Pursuit of DEI," may be of interest beyond tax and nonprofit folk, I share the SSRN link here: papers.ssrn.com/sol3/papers....
Revoking Tax-Exemption for Pursuit of DEI
<div> These have been hard times for section 501(c)(3) organizations that believe in DEI. President Trump, unhappy with Harvard’s University’s refusal to agree
papers.ssrn.com
April 28, 2025 at 4:41 PM
ellenaprill.bsky.social
My new piece for The Convesation: Endowments aren’t blank checks – but universities can rely on them more heavily in turbulent times theconversation.com/endowments-a...
Endowments aren’t blank checks – but universities can rely on them more heavily in turbulent times
Most institutions of higher education have more freedom to spend from their endowments than they may realize.
theconversation.com
April 21, 2025 at 9:53 PM
ellenaprill.bsky.social
Honored to have been quoted at length in this Chronicle of Philanthropy piece.
uclalawlmpn.bsky.social Lowell Milken Center for Philanthropy and Nonprofits at UCLA Law @uclalawlmpn.bsky.social · Apr 14
In the Chronicle of Philanthropy's latest report on the Gates Foundation’s decision to open its scholarship program to students of all races, Ellen Aprill offers legal insight on nonprofit tax law and the role of public policy in evaluating charitable activity.
ucla.box.com/s/dzd9uy5iki...
Faced With Anti-DEI Complaint, Gates Opens Scholarship to White Students.pdf | Powered by Box
ucla.box.com
April 14, 2025 at 11:21 PM
ellenaprill.bsky.social
See this important coverage of the Gates Foundation reaction to a challenge to its minority scholarship program. Pleased to be quoted in the piece. www.philanthropy.com/article/gate...
Faced With Anti-DEI Complaint, Gates Foundation Opens Scholarship to White Students
After Edward Blum’s complaint to the IRS about the Gates Foundation’s “illegal” scholarship program for students of color, the Seattle philanthropy giant said it would change the scholarship’s eligibi...
www.philanthropy.com
April 14, 2025 at 4:43 PM
ellenaprill.bsky.social
My short piece on the current United States Institute of Piece controversy
March 21, 2025 at 3:08 PM
ellenaprill.bsky.social
The famous "First They Came" poem, an important reminder in these days: hmd.org.uk/resource/fir...
Holocaust Memorial Day Trust | First They Came – by Pastor Martin Niemöller
First They Came is a poem by Pastor Martin Niemoller
hmd.org.uk
March 16, 2025 at 2:48 PM
ellenaprill.bsky.social
Thank you, Dean Treanor. Ellen Aprill, GULC 1980
joshchafetz.bsky.social Josh Chafetz @joshchafetz.bsky.social · Mar 6
With his permission, I'm sharing Dean Treanor's response to Ed Martin's letter:
March 6, 2025 at 8:41 PM
ellenaprill.bsky.social
A short piece on the implications of the delegated authority examples in Loper Bright:
www.yalejreg.com/nc/unpacking...
Unpacking the Most Important Paragraph in Loper Bright, by Ellen P. Aprill - Yale Journal on Regulation
Loper Bright Enterprises v. Raimondo, of course, overruled Chevron v. NRDC, ending judicial deference to administrative agencies conferred by ambiguous statutory language. The opinion also acknowledge...
www.yalejreg.com
January 15, 2025 at 6:42 PM
ellenaprill.bsky.social
So honored to have received, along with Beverly Moran, a lifetime achievement award from the Tax Section of the American Association of Law Schools.
taxprof.typepad.com/taxprof_blog...
January 13, 2025 at 6:59 PM
ellenaprill.bsky.social
My new piece with @jillh.bsky.social and Rose Chan Loui on the OpenAI saga and its charitable obligations. #nonprofits #philanthropy. theconversation.com/legal-compli...
Legal complications await if OpenAI tries to shake off control by the nonprofit that owns the rapidly growing tech company
When for-profit companies are spun out of nonprofits, there is no easy way out of the legal consequences.
theconversation.com
November 20, 2024 at 3:09 PM
Reposted by EllenAprill.bsky.social
jillh.bsky.social
My 2 cents on OpenAI's attempt to dump its charitable obligations. With @ellenaprill.bsky.social and Rose Chan Loui
nam10.safelinks.protection.outlook.com?url=https%3A...
Legal complications await if OpenAI tries to shake off control by the nonprofit that owns the rapidly growing tech company
When for-profit companies are spun out of nonprofits, there is no easy way out of the legal consequences.
nam10.safelinks.protection.outlook.com
November 20, 2024 at 2:14 PM
ellenaprill.bsky.social
November 16, 2024 at 11:29 PM