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(f) Exempted Activities

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Certain business activities conducted by tax-exempt organizations are exempt from unrelated business taxation. These include:

 A trade or business “in which substantially all the work in carrying on such trade or business is performed for the organization without compensation.”546

 A trade or business carried on by the organization primarily for the “convenience of its members, students, patients, officers, or employees.”547 This exemption is available only to organizations that are charitable entities548 or are governmental colleges and universities.549

 A trade or business “which is the selling of merchandise, substantially all of which has been received by the organization as gifts or contributions.”550

 Qualified public entertainment activities,551 which are “any entertainment or recreational activity of a kind traditionally conducted at fairs or expositions promoting agricultural and educational purposes, including, but not limited to, any activity one of the purposes of which is to attract the public to fairs or expositions or to promote the breeding of animals or the development of products or equipment.”552 This exemption is available only to charitable, social welfare, labor, and agricultural organizations.553

 Qualified convention and trade show activities,554 which are “any activity of a kind traditionally conducted at conventions, annual meetings, or trade shows, including, but not limited to, any activity one of the purposes of which is to attract persons in an industry generally (without regard to membership in the sponsoring organization) as well as members of the public to the show for the purpose of displaying industry products or to stimulate interest in, and demand for, industry products or services, or to educate persons engaged in the industry in the development of new products and services or new rules and regulations affecting the industry.”555 This exemption is available only to charitable, social welfare, labor, and agricultural organizations and to business leagues.556

 In the case of a charitable hospital, the furnishing of certain cooperative services to one or more small hospitals under certain circumstances.557

 The conduct of certain bingo games.558

 In the case of charitable and veterans' organizations, contributions to which are deductible for federal income tax purposes,559 activities relating to the distribution of low-cost articles if the distribution of the articles is incidental to the solicitation of charitable contributions.560

 In the case of charitable and veterans' organizations, contributions to which are deductible for federal income tax purposes, any trade or business consisting of (1) exchanging, with another of these organizations, names and addresses of donors to or members of the organization or (2) renting the names and addresses to another of these organizations.561

The Tax Law of Charitable Giving

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