Donations to nonprofits and government

From the 2024 DOR Tax Exemption Study

Det. No. 18-0307, 40 WTD 077 (April 5, 2021) 81 International Dictionary 992 (3rd ed. 1993). The recipients of the incentive payments here were not freely given money from the federal government, but instead were incentivized to apply for the program through the promise of compensation, had to attest to their “meaningful use” of electronic health records in order to receive compensation through the incentive payments, and, if they did not participate, they risked losing money in the form of reduced Medicare or Medicaid reimbursement rates. As we must “narrowly construe” exemption statutes, we hold that the incentive payments here lack the “gratuitous purpose” discussed in Analytical Methods. The incentive payments were not “given freely,” but instead were given with strict compliance requirements and in lieu of a punitive measure for noncompliance. Further, the electronic health records program was designed to move medical providers from using paper medical records to using digital medical records. The purpose of the program was to modernize American medical records, as envisioned by the federal government. Pub. L. No. 111-5, 123 Stat. 230. We hold that the incentive payments here