Elinor Ramey

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Elinor Ramey advises public charities, private foundations, and other tax-exempt organizations on tax and governance matters. She also works closely with high-net-worth individuals on developing and implementing the most efficient and effective ways to advance their philanthropic objectives.

A former attorney and policy advisor for the U.S. Treasury Department, Elinor’s practice focuses on structuring organizations to receive and maintain exempt status, addressing issues such as unrelated business income tax, excess benefit transactions, and the various excise taxes that impact exempt organizations. She advises on matters related to tax planning, tax controversy, and voluntary disclosures; compliance with state charity laws and regulations; and the tax issues involved in political campaign activity. She also has significant experience counseling on corporate governance and fiduciary duties of exempt organizations.

While at the Treasury Department, Elinor advised the Assistant Secretary for Tax Policy on all legal and policy matters involving tax-exempt organizations and charitable contributions. She was instrumental in the development of tax guidance affecting charities, in particular implementation of the Tax Cuts and Jobs Act, and regulations on the unrelated business income tax, executive compensation, and the net investment income tax on colleges and universities. Elinor also worked on guidance projects relating to program related investments, mission related investing, private foundations, donor advised funds, conservation easements, substantiation of charitable contributions, and supporting organizations.

Elinor has extensive experience working on the development of guidance with the Treasury Department and the IRS, and with legislative bodies, including the U.S. House Committee on Ways & Means, Senate Finance Committee, and the Joint Committee on Taxation. She is a frequent speaker at conferences focused on exempt organizations.