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Wisdom & Insight

This month's question addresses the apparent challenge related to nonprofit organizations use of the word "tourism." To date, nonprofit organizations have utilized the phrase "Volunteer Vacations" to describe the voluntary service experiences that they create throughout the world.

Why would nonprofit organizations be challenged by adopting the word "tourism" to describe the products and services that they offer, if, in fact, travel and tourism are incorporated into the overall experience?

In order to answer this question, I thought it would be important to connect with someone that has a track record of relating to nonprofit organizations, especially in the area of volunteerism.

Mary Merrill of Merrill Associates has a track record of working with nonprofit organizations and NGOs. In fact, this month she wrote an article on VolunTourism in her newsletter that is featured in our September VT-Lines.

This was her immediate response:

We talked some about the reluctance of nonprofits to be involved and we tend to think it is because they worry about it being counted as unrelated business income, which causes problems with the IRS. Also, they do not see it as a function of their mission. Of course, we think this can be addressed.

UBIT (Unrelated Business Income Tax) is a tax imposed on the unrelated income generated by tax-exempt organizations.

According to the website of Kern, DeWenter, & Viere, Ltd.'s website:

"Nonprofit organizations don’t have to pay income tax because they’re statutorily exempt. But they have to pay income tax on the profits they make from regularly carried on business activities unrelated to their exempt purpose. This is to avoid promoting unfair competition by nonprofits. The tax rate is the same that a corporation would pay and is calculated in nearly the same way. And the Internal Revenue Code (IRC) specifically excludes the first $1,000 of unrelated business income from tax.

The IRS issues rules interpreting the UBIT provisions in the tax code and the courts further interpret the rules to settle disputes. Although an exempt organization must be operated primarily for its exempt purpose, it may carry on some unrelated business activities without jeopardizing its exempt status."

This speaks exactly to Mary's comments. Yet it is evident that UBIT was established with the intent of preventing nonprofit organizations and NGOs from holding a competitive advantage over other businesses. Certainly members of the tourism industry could challenge the activities of nonprofit organizations if it was discovered that "Volunteer Vacations" were products and services that fall outside of the parameters of their mission, yet were not being subjected to UBIT.

Thus, we have the following dilemma for nonprofit organizations: "How much of the current services being offered by our nonprofit organization fall under the category of being subject to UBIT?" And is this sufficient enough reason to reject the notion that the operations of the nonprofit organization are indeed connected to tourism?

This is a question upon which hopefully our NGO subcribers can shed some light. For example, museums, zoos, and other entities may have dealt with these issues in the past and they may be excellent resources to provide us with their insight.

Likely we will revisit this subject in a future issue.

Mary Merrill teaches the Institute for Community Leadership and Volunteer Administration at The Ohio State University. She is working with developing NGOs (non-governmental organizations) in Armenia , and helped develop a volunteer center in Moscow , Russia . She coordinated international study abroad projects for Ohio State University Leadership Center and North Carolina State University 4-H.

Mary is a member of The International Association for Volunteer Effort (IAVE), The International Association for Volunteer Administration (AVA), the Association for Research on Nonprofit Organizations and Voluntary Action (ARNOVA), the Points of Light Foundation, the Ohio Association of Volunteer Administrations and the Volunteer Administrators Network of Central Ohio. Mary has received numerous awards for her contributions to her profession and her community.

Mary is a dynamic, engaging speaker and a skilled facilitator. She has been a featured speaker at three World Volunteer Conferences and has worked with a wide range of organizations in the United States , Canada , Russia , Armenia , Venezuela , Mexico , Brazil and the United Kingdom . She designs strategic planning processes, employee development seminars, and serves as a consultant to nonprofit organizations and professional associations.

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