Lowell Milken Center for Philanthropy and Nonprofits at UCLA Law
@uclalawlmpn.bsky.social
At the Lowell Milken Center for Philanthropy and Nonprofits, our mission is to enhance the understanding of the philanthropy and nonprofit sector and to support it through leading-edge education, thought leadership, and research.
In the The Chronicle of Philanthropy's recent article on the legality of Donald Trump’s directive to target liberal groups and progressive nonprofits, Ellen Aprill offers insight into the limits of IRS authority and the potential misuse of nonprofit tax law.
www.philanthropy.com/article/trum...
www.philanthropy.com/article/trum...
Trump’s Order to Investigate Liberal Groups Is Likely to Face Legal Challenges
President Trump’s order calling for a broad offensive against domestic terrorism groups — and the foundations the White House alleges support them — are bound to face legal and regulatory challenges, ...
www.philanthropy.com
October 7, 2025 at 10:27 PM
In the The Chronicle of Philanthropy's recent article on the legality of Donald Trump’s directive to target liberal groups and progressive nonprofits, Ellen Aprill offers insight into the limits of IRS authority and the potential misuse of nonprofit tax law.
www.philanthropy.com/article/trum...
www.philanthropy.com/article/trum...
In a new podcast episode with @taxnotes.com, Ellen Aprill discusses the Trump Administration’s ploy to revoke Harvard’s tax-exempt status, raising questions about the safety nets that tax-exempt organizations may have if the revocation goes through.
taxnotestalk.taxnotes.com/124942/episo...
taxnotestalk.taxnotes.com/124942/episo...
Harvard vs. Trump: The Battle Over Tax-Exempt Status - Tax Notes Talk
Ellen Aprill of UCLA discusses the legal battle between Harvard and the Trump administration over the university's tax-exempt status and the recourses that an exempt organization may have if its status is revoked.For more, read Aprill's article, "...
taxnotestalk.taxnotes.com
August 15, 2025 at 7:05 PM
In a new podcast episode with @taxnotes.com, Ellen Aprill discusses the Trump Administration’s ploy to revoke Harvard’s tax-exempt status, raising questions about the safety nets that tax-exempt organizations may have if the revocation goes through.
taxnotestalk.taxnotes.com/124942/episo...
taxnotestalk.taxnotes.com/124942/episo...
A new publication by LMPN’s Ellen Aprill highlights the proposed order and joint motion for entry of consent judgment in National Religious Broadcasters v. Commissioner addressing the relationship between the Johnson Amendment and houses of worship.
papers.ssrn.com/sol3/papers....
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 14, 2025 at 7:09 PM
A new publication by LMPN’s Ellen Aprill highlights the proposed order and joint motion for entry of consent judgment in National Religious Broadcasters v. Commissioner addressing the relationship between the Johnson Amendment and houses of worship.
papers.ssrn.com/sol3/papers....
papers.ssrn.com/sol3/papers....
We were so thrilled to speak with so many ambitious incoming Masters of Legal Studies students at their orientation for UCLA School of Law yesterday. Looking forward to seeing all these bright minds on campus!
@uclalaw.bsky.social
@uclalaw.bsky.social
August 6, 2025 at 5:27 PM
We were so thrilled to speak with so many ambitious incoming Masters of Legal Studies students at their orientation for UCLA School of Law yesterday. Looking forward to seeing all these bright minds on campus!
@uclalaw.bsky.social
@uclalaw.bsky.social
Founding Executive Director, Rose Chan Loui, shared her nonprofit law expertise with Bloomberg Law regarding the IRS’s recent denial of an open-source company’s application for tax-exempt status.
Read the full article below!
ucla.box.com/s/hxu69480l5...
Read the full article below!
ucla.box.com/s/hxu69480l5...
Open-Source Software Groups Fa.pdf | Powered by Box
ucla.box.com
August 5, 2025 at 7:35 PM
Founding Executive Director, Rose Chan Loui, shared her nonprofit law expertise with Bloomberg Law regarding the IRS’s recent denial of an open-source company’s application for tax-exempt status.
Read the full article below!
ucla.box.com/s/hxu69480l5...
Read the full article below!
ucla.box.com/s/hxu69480l5...
Ellen Aprill recently joined the BradCast to discuss the Trump Administration's IRS declaring it lawful for churches to endorse candidates from the pulpit, contradicting 75-years of tax law regarding the separation of church and state. Listen to the full podcast episode at the BradBlog.com!
The BRAD BLOG
Guest: Tax law Prof. Ellen Aprill; Also: AZ's special House primary; Inflation up as tariffs take hold; Tax dodge specialist writing tax policy...
BradBlog.com
July 16, 2025 at 9:25 PM
Ellen Aprill recently joined the BradCast to discuss the Trump Administration's IRS declaring it lawful for churches to endorse candidates from the pulpit, contradicting 75-years of tax law regarding the separation of church and state. Listen to the full podcast episode at the BradBlog.com!
Following the I.R.S. saying that the ban on tax-exempt organizations campaigning for candidates should not apply to churches speaking to their own members, Ellen Aprill asserts that limitations on the audience of these campaigns will not hold long term.
Read more:
www.nytimes.com/2025/07/07/u...
Read more:
www.nytimes.com/2025/07/07/u...
I.R.S. Says Churches Can Endorse Candidates From the Pulpit
www.nytimes.com
July 8, 2025 at 8:57 PM
Following the I.R.S. saying that the ban on tax-exempt organizations campaigning for candidates should not apply to churches speaking to their own members, Ellen Aprill asserts that limitations on the audience of these campaigns will not hold long term.
Read more:
www.nytimes.com/2025/07/07/u...
Read more:
www.nytimes.com/2025/07/07/u...
Founding Faculty Director, Jill Horwitz, adds to the conversation about Open AI's limited time to reach a deal regarding their plans to transform their for-profit arm into a public benefit corporation.
Read the full article in Yahoo Finance: finance.yahoo.com/news/a-20-bi...
Read the full article in Yahoo Finance: finance.yahoo.com/news/a-20-bi...
A $20 billion clock is ticking for OpenAI as Microsoft talks turn fractious
The romance between Microsoft and OpenAI is reportedly showing cracks.
finance.yahoo.com
June 20, 2025 at 8:43 PM
Founding Faculty Director, Jill Horwitz, adds to the conversation about Open AI's limited time to reach a deal regarding their plans to transform their for-profit arm into a public benefit corporation.
Read the full article in Yahoo Finance: finance.yahoo.com/news/a-20-bi...
Read the full article in Yahoo Finance: finance.yahoo.com/news/a-20-bi...
Mill Law Center recently launched their Defending Equity Initiative - a new nonprofit organization that will offer pro bono legal services for 501(c)(3) organizations targeted for their DEI programs, support of immigrants, or other progressive work.
Learn more: www.defendingequity.org
Learn more: www.defendingequity.org
June 18, 2025 at 11:15 PM
Mill Law Center recently launched their Defending Equity Initiative - a new nonprofit organization that will offer pro bono legal services for 501(c)(3) organizations targeted for their DEI programs, support of immigrants, or other progressive work.
Learn more: www.defendingequity.org
Learn more: www.defendingequity.org
Join us in welcoming Shahani Waas, M.A. as our new Center Manager at the Lowell Milken Center for Philanthropy and Nonprofits! With nearly a decade of experience at UCLA, she brings to the center blend of strategic vision, budget savvy, and a passion for empowering the next generation.
June 10, 2025 at 5:51 PM
Join us in welcoming Shahani Waas, M.A. as our new Center Manager at the Lowell Milken Center for Philanthropy and Nonprofits! With nearly a decade of experience at UCLA, she brings to the center blend of strategic vision, budget savvy, and a passion for empowering the next generation.
In Boston Globe Media, Jill Horwitz sheds light on one of Harvard’s most powerful tools: its endowment. Under Massachusetts law, there is a legal “escape valve” that could allow the university to access even donor-restricted funds in emergencies.
www.bostonglobe.com/2025/05/31/m...
www.bostonglobe.com/2025/05/31/m...
Can Harvard outlast the Trump administration and its unrelenting onslaught? - The Boston Globe
President Trump is trying to apply enough pressure to force the university to cave, while Harvard, a nearly 400-year-old institution, is aiming to play a long game against an aging president in his fi...
www.bostonglobe.com
June 2, 2025 at 8:27 PM
In Boston Globe Media, Jill Horwitz sheds light on one of Harvard’s most powerful tools: its endowment. Under Massachusetts law, there is a legal “escape valve” that could allow the university to access even donor-restricted funds in emergencies.
www.bostonglobe.com/2025/05/31/m...
www.bostonglobe.com/2025/05/31/m...
Speaking with @theinformation.com, LMPN's Rose Chan Loui takes a hard look at OpenAI’s revised plan to convert its for-profit arm into a public benefit corporation and the growing pushback from nonprofit watchdogs.
www.theinformation.com/articles/ope...
www.theinformation.com/articles/ope...
OpenAI’s New Path to Conversion Faces Activist Opposition
OpenAI has backed off on its plans to carve out its for-profit business, which is responsible for ChatGPT, from its nonprofit charity arm. However, OpenAI’s new proposal to restructure its ownership h...
www.theinformation.com
May 29, 2025 at 11:48 PM
Speaking with @theinformation.com, LMPN's Rose Chan Loui takes a hard look at OpenAI’s revised plan to convert its for-profit arm into a public benefit corporation and the growing pushback from nonprofit watchdogs.
www.theinformation.com/articles/ope...
www.theinformation.com/articles/ope...
Ellen Aprill co-authors a response to commentary on Harvard University’s tax-exempt status, emphasizing that while public policy can shift with political leadership, fundamental public policy reflects enduring national values that transcend administrations.
papers.ssrn.com/sol3/papers....
papers.ssrn.com/sol3/papers....
Harvard Does Have Options if It Loses Tax-Exempt Status
As scholars of nonprofit, tax-exempt organizations, we wish to take issue with Marie Sapirie’s recent article, Harvard Has a Precedent Problem in Fight to
papers.ssrn.com
May 28, 2025 at 6:09 PM
Ellen Aprill co-authors a response to commentary on Harvard University’s tax-exempt status, emphasizing that while public policy can shift with political leadership, fundamental public policy reflects enduring national values that transcend administrations.
papers.ssrn.com/sol3/papers....
papers.ssrn.com/sol3/papers....
Rose Chan Loui warns that as OpenAI’s nonprofit governance gives way to profit-driven imperatives, mission-driven organizations must reckon with the challenge of aligning public-interest goals and corporate partnerships. (Translated from the original article in NIKKEI)
ucla.box.com/s/y72ev7jtjj...
ucla.box.com/s/y72ev7jtjj...
NIKKEI Digital Governance Article with Rose Chan Loui.pdf | Powered by Box
NIKKEI Digital Governance Article with Rose Chan Loui.pdf | Powered by Box
ucla.box.com
May 27, 2025 at 10:28 PM
Rose Chan Loui warns that as OpenAI’s nonprofit governance gives way to profit-driven imperatives, mission-driven organizations must reckon with the challenge of aligning public-interest goals and corporate partnerships. (Translated from the original article in NIKKEI)
ucla.box.com/s/y72ev7jtjj...
ucla.box.com/s/y72ev7jtjj...
As universities face deepening financial pressure from federal research funding cuts and a proposed 21% tax on endowment earnings, LMPN's Founding Faculty Director, Jill Horwitz, offers a timely legal roadmap in her latest Bloomberg Law article.
Read more: news.bloombergtax.com/tax-insights...
Read more: news.bloombergtax.com/tax-insights...
Universities Hit by US Funding Drain Have Legal Means to Recover
Opinion: UCLA School of Law's Jill Horwitz says there are legal ways that universities can tap their endowments to protect themselves against federal funding cuts and plans for up to a 21% endowment t...
news.bloombergtax.com
May 22, 2025 at 6:50 PM
As universities face deepening financial pressure from federal research funding cuts and a proposed 21% tax on endowment earnings, LMPN's Founding Faculty Director, Jill Horwitz, offers a timely legal roadmap in her latest Bloomberg Law article.
Read more: news.bloombergtax.com/tax-insights...
Read more: news.bloombergtax.com/tax-insights...
Last week, the Lowell Milken Center for Philanthropy and Nonprofits hosted the half day conference "Nonprofit Arts: Creative Leadership in Uncertain Times". Thank you to our speakers for bringing your insight to this event and to all who continue to advance the role of the arts in public life.
May 19, 2025 at 10:30 PM
Last week, the Lowell Milken Center for Philanthropy and Nonprofits hosted the half day conference "Nonprofit Arts: Creative Leadership in Uncertain Times". Thank you to our speakers for bringing your insight to this event and to all who continue to advance the role of the arts in public life.
In this week’s Transformer Weekly, a spotlight is cast on OpenAI’s proposed restructuring into a public benefit corporation. While the company claims its nonprofit parent will retain “control,” LMPN's Rose Chan Loui is hoping for more clarity sometime soon.
www.transformernews.ai/p/who-will-c...
www.transformernews.ai/p/who-will-c...
Who will ‘control’ OpenAI?
Transformer Weekly: OpenAI’s for-profit plans, Fidji Simo’s new role, and the end of the diffusion rule
www.transformernews.ai
May 12, 2025 at 9:56 PM
In this week’s Transformer Weekly, a spotlight is cast on OpenAI’s proposed restructuring into a public benefit corporation. While the company claims its nonprofit parent will retain “control,” LMPN's Rose Chan Loui is hoping for more clarity sometime soon.
www.transformernews.ai/p/who-will-c...
www.transformernews.ai/p/who-will-c...
In a new piece from Axios, LMPN's Ellen Aprill and Jill Horwitz weigh in on how OpenAI’s unique nonprofit/for-profit structure opens the door to regulatory oversight by state attorneys general, especially in California.
Read more of their insights here: www.axios.com/2025/05/08/o...
Read more of their insights here: www.axios.com/2025/05/08/o...
OpenAI governance opens it to state AG pressure
OpenAI announced this week that control will continue to be held by a nonprofit.
www.axios.com
May 9, 2025 at 11:50 PM
In a new piece from Axios, LMPN's Ellen Aprill and Jill Horwitz weigh in on how OpenAI’s unique nonprofit/for-profit structure opens the door to regulatory oversight by state attorneys general, especially in California.
Read more of their insights here: www.axios.com/2025/05/08/o...
Read more of their insights here: www.axios.com/2025/05/08/o...
Rose Chan Loui continues to be a leading voice in the national conversation on OpenAI’s governance reversal. In a new Promarket piece, she unpacks what OpenAI’s sudden decision to retain nonprofit control really means and what questions still remain.
www.promarket.org/2025/05/06/o...
www.promarket.org/2025/05/06/o...
OpenAI Abandons Move to For-Profit Status After Backlash. Now What? - ProMarket
After public backlash, OpenAI has abandoned plans to restructure to remove control by its nonprofit entity. ProMarket reviews the history of OpenAI’s internal tensions to pursue profits over its found...
www.promarket.org
May 9, 2025 at 11:36 PM
Rose Chan Loui continues to be a leading voice in the national conversation on OpenAI’s governance reversal. In a new Promarket piece, she unpacks what OpenAI’s sudden decision to retain nonprofit control really means and what questions still remain.
www.promarket.org/2025/05/06/o...
www.promarket.org/2025/05/06/o...
In this new 80,000 Hours episode breaks down the nonprofit governance crisis at OpenAI and what’s at stake for public safety, accountability, and the role of state oversight in the AI era.
Listen here: 80000hours.org/podcast/epis...
Listen here: 80000hours.org/podcast/epis...
Emergency pod: Did OpenAI give up, or is this just a new trap? (with Rose Chan Loui)
80000hours.org
May 9, 2025 at 8:39 PM
In this new 80,000 Hours episode breaks down the nonprofit governance crisis at OpenAI and what’s at stake for public safety, accountability, and the role of state oversight in the AI era.
Listen here: 80000hours.org/podcast/epis...
Listen here: 80000hours.org/podcast/epis...
LMPN at UCLA Law's Rose Chan Loui continues to contribute expert analysis across major news platforms regarding OpenAI’s decision to retain nonprofit control amidst its restructuring as a public benefit corporation.
Read more via Bloomberg:
www.bloomberg.com/news/article...
@uclalaw.bsky.social
Read more via Bloomberg:
www.bloomberg.com/news/article...
@uclalaw.bsky.social
OpenAI Walks Back For-Profit Plan, Nonprofit to Keep Control
OpenAI is backtracking on plans to become a more conventional for-profit company after facing mounting pressure from former employees, academics and rivals, including billionaire Elon Musk.
www.bloomberg.com
May 7, 2025 at 3:28 PM
LMPN at UCLA Law's Rose Chan Loui continues to contribute expert analysis across major news platforms regarding OpenAI’s decision to retain nonprofit control amidst its restructuring as a public benefit corporation.
Read more via Bloomberg:
www.bloomberg.com/news/article...
@uclalaw.bsky.social
Read more via Bloomberg:
www.bloomberg.com/news/article...
@uclalaw.bsky.social
In a recent article by Business Insider, Rose Chan Loui discusses Open AI's restructuring of its for-profit arm as a Public Benefit Corporation - allowing the nonprofit to retain legal control and a significant financial stake.
Read the full piece below:
www.businessinsider.com/openais-new-...
Read the full piece below:
www.businessinsider.com/openais-new-...
OpenAI thinks it has defused its multibillion-dollar time bomb
OpenAI needs to restructure itself or lose billions of dollars. It thinks it has a new solution. Experts are skeptical.
www.businessinsider.com
May 6, 2025 at 11:56 PM
In a recent article by Business Insider, Rose Chan Loui discusses Open AI's restructuring of its for-profit arm as a Public Benefit Corporation - allowing the nonprofit to retain legal control and a significant financial stake.
Read the full piece below:
www.businessinsider.com/openais-new-...
Read the full piece below:
www.businessinsider.com/openais-new-...
Rose Chan Loui shared her insights on OpenAI’s latest restructuring move - opting to have its nonprofit continue controlling the organization despite transforming its for-profit arm into a public benefit corporation (PBC).
Read more below:
techcrunch.com/2025/05/06/w...
Read more below:
techcrunch.com/2025/05/06/w...
What OpenAI's restructuring plan means for its corporate future | TechCrunch
OpenAI's new restructuring plan has implciations for its corporate future, especially if the organization hopes to one day IPO.
techcrunch.com
May 6, 2025 at 11:26 PM
Rose Chan Loui shared her insights on OpenAI’s latest restructuring move - opting to have its nonprofit continue controlling the organization despite transforming its for-profit arm into a public benefit corporation (PBC).
Read more below:
techcrunch.com/2025/05/06/w...
Read more below:
techcrunch.com/2025/05/06/w...
Speaking with The Associated Press, Rose Chan Loui continues to weigh in on OpenAI's decision to keep its nonprofit in charge. This shift follows a months-long debate over the company's governance structure.
Read more here:
apnews.com/article/open...
Read more here:
apnews.com/article/open...
OpenAI reverses course and says its nonprofit will continue to control its business
OpenAI is reversing course and said Monday its nonprofit will continue to control the business that makes ChatGPT and other artificial intelligence products.
apnews.com
May 6, 2025 at 10:24 PM
Speaking with The Associated Press, Rose Chan Loui continues to weigh in on OpenAI's decision to keep its nonprofit in charge. This shift follows a months-long debate over the company's governance structure.
Read more here:
apnews.com/article/open...
Read more here:
apnews.com/article/open...
In the Washington Post's coverage of OpenAI’s controversial governance debate, Jill Horwitz provided legal insight into the implications of the company’s decision to preserve nonprofit oversight.
Read the full article here:
www.washingtonpost.com/technology/2...
Read the full article here:
www.washingtonpost.com/technology/2...
Sam Altman hands Elon Musk a win, scrapping OpenAI’s for-profit plan
ChatGPT maker OpenAI said it will no longer seek to restructure into a for-profit company separate from its nonprofit board, a move Elon Musk had sought to block.
www.washingtonpost.com
May 6, 2025 at 10:03 PM
In the Washington Post's coverage of OpenAI’s controversial governance debate, Jill Horwitz provided legal insight into the implications of the company’s decision to preserve nonprofit oversight.
Read the full article here:
www.washingtonpost.com/technology/2...
Read the full article here:
www.washingtonpost.com/technology/2...