Casner & Edwards

Sharon C. Lincoln

  • Managed IRS audits for a major university, an established private foundation, a multi-million dollar international charity, and an educational institution. 
  • Advised a multi-million dollar health services provider based in California with IRS and governance matters.
  • Currently assisting clients in litigation matters in Tax Court and in Massachusetts Probate Court.
  • Routinely assists foreign charitable organizations with tax opinions related to their qualification as organizations described in Section 501(c) of the Internal Revenue Code. 
  • Represented several tax-exempt organizations in connection with investigations by or filings with the Nonprofit Organizations/Public Charities Division of the Office of Attorney General.
  • Provided guidance regarding office reopening guidelines and best practices in the midst of the COVID-19 pandemic.
  • Assisted with the establishment of one of the first Massachusetts benefit corporations and with numerous Delaware public benefit corporations. 
  • Co-wrote a tax opinion for a large nonprofit organization that discussed the requirements for the organization’s on-going qualification as a tax-exempt organization. Subsequently assisted the organization with forming a for-profit subsidiary to conduct activities that fall outside of the client’s charitable mission. 
  • Represented a private foundation organized in the United Kingdom in establishing operations in the United States without incurring federal or state tax reporting obligations.
  • Represented a large conservation organization in negotiating and drafting an affiliation agreement with another longstanding conservation organization that aligned their operations and financial management. 
  • Assisted several tax-exempt organizations with structuring and executing asset acquisitions and mergers. 
  • Assisted several different charities with structuring relationships (joint ventures, partnerships, etc.) with non-charitable entities. 
  • Assisted an established healthcare nonprofit with streamlining its board governance, charter, and bylaws to align with Type I supporting organization qualification. 
  • Advised several national charitable organizations regarding the federal tax laws regulating the participation of such charitable organizations in lobbying activities, including the expenditure test under Code section 501(h). 
  • Provided a large tax-exempt healthcare organization with guidance regarding the excess benefit rules as they applied to compensation paid to the organization’s executives. 
  • Assisted a national microfinance organization with structuring matters.
  • Provided specific guidance regarding maintaining tax-exempt status to several national charities that were undergoing (or considering) significant restructuring. 
  • Assisted a large tax-exempt healthcare organization with tax aspects related to making a renewable energy investment. 
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