Organizations exempt from federal income taxes under section 501(c)(3) of the IRS code are “organized and operated exclusively for religious, charitable, and scientific…or educational purposes.” (The statute includes four other narrower purposes.) Since the statute doesn’t define “charitable” with any precision, one is left to look elsewhere for a definition.
Hopkins identifies two sources: the “popular and ordinary” meaning that is limited to the relief of the poor, and the “common law meaning” (1992, p.70-74) The common law meaning is derived from the English Statute of Charitable Uses of 1601, which in turn drew from earlier holdings and cultural understandings, and includes the broad range of activities that benefit the general welfare or the community. It is this latter broad definition that is considered appropriate when assessing the aims of 501(c)(3) activity.
Sources:
Bruce R. Hopkins, The Law of Tax-Exempt Organizations (6th Edition, 1992 (pp.70-74), or other editions) (John Wiley & Sons)
IRS Code, sections 170 and 501(c)(3).
KEY WORDS: LEGAL DEFINITIONS