Practice Areas · Tax · Tax-Exempt Organizations

Tax-Exempt Organizations Recruiters

Tax-exempt organizations recruiters for law firms, universities, hospitals, foundations, and associations. In fiscal 2025 the IRS recognized 1,916,367 section 501(c) organizations and closed 145,202 applications for exemption. For taxable years beginning after 31 December 2025, section 4968 taxes some private-college investment income at 1.4, 4, or 8 percent.

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Tax-exempt organizations recruiters place lawyers who qualify, maintain, and defend exemption under the Internal Revenue Code. In fiscal 2025 the IRS recognized 1,916,367 section 501(c) organizations, closed 145,202 applications for tax-exempt status, and examined 889 Forms 990, 990-EZ, and 990-N (Data Book, April 2026). Sartori & Partners closed 14 tax-exempt-organization searches from October 2023 through September 2026. A private research university in Boston hired its first general counsel in 12 weeks.

01 Market intelligence

The exempt-organization book firms and charities are hiring against.

Figures below are the IRS fiscal 2025 master file, the determination docket, and the filing count. They describe the work.

1,916,367
section 501(c) organizations recognized in fiscal 2025
IRS Data Book, Table 2-6, April 2026
145,202
applications for tax-exempt status closed in fiscal 2025
IRS Data Book, Table 2-4, April 2026
1.4 / 4 / 8%
section 4968 rates for years beginning after 31 Dec 2025
Public Law 119-21, section 70415

In fiscal 2025, which ran from 1 October 2024 through 30 September 2025, the IRS recognized 1,916,367 organizations as exempt under section 501(c) (IRS Data Book, 2025, Publication 55-B, April 2026, Table 2-6). Of those, 1,596,231 were section 501(c)(3) religious, charitable, and similar organizations. That line includes private foundations and organizations covered by a group exemption letter. It excludes churches and very small charities that never applied for recognition. Section 501(c)(4) social welfare organizations numbered 69,617. Section 501(c)(6) business leagues numbered 57,916. Adding 239 section 501(d) religious and apostolic associations, 49,048 section 527 political organizations, and 103,087 nonexempt charitable and split-interest trusts, the master file covered 2,068,741 entities. A search that says “nonprofit lawyer” and means all of those subsections will interview the wrong half of the bar.

The IRS closed 145,202 applications for tax-exempt status in fiscal 2025. It approved 128,642, which is the 88.6 percent the Data Book reports, disapproved 149, and closed another 16,411 as withdrawn, incomplete, or otherwise unresolved (Table 2-4). Those three dispositions add to 145,202. Section 501(c)(3) accounted for 137,543 of the closures and 121,913 of the approvals. The table is not a count of first-time Forms 1023 alone. Footnote 1 includes public-charity and private-foundation status determinations, advance approval of scholarship procedures, and group determinations. A requisition for “someone who has gotten an exemption letter” has to name which of those products the lawyer has signed.

Exempt organizations filed 1,798,413 returns in fiscal 2025, down 0.4 percent from 1,805,833 in fiscal 2024 (Table 1-2). Against that filing volume, Table 3-5 records 889 examinations of Forms 990, 990-EZ, and 990-N, 77 examinations of Form 990-T (the unrelated business income return), and 188 examinations of Form 4720 (the return used for excise taxes on exempt organizations and related persons). A separate line, Forms 990-PF, 1041-A, 1120-POL, and 5227 together, was 77 examinations. The wider Tax Exempt and Government Entities count, which also includes employee plans, government entities, and tax-exempt bonds, was 7,914 returns. The 2026 hiring pressure is the determination, the information return, and the excise computation. Corporate field-exam defense is a different instruction, on tax planning and controversy.

Sartori & Partners maps 1,480,000+ lawyers. A tax-exempt organizations search is drawn from the slice of that field whose matters are qualification, the annual information return, private-foundation excise taxes, unrelated business income, and the compensation and endowment excises. The parent tax practice covers planning and controversy together. The nonprofit practice covers governance, grants, and how these organizations actually run. This page is the Code.

02 Demand

What is putting exempt-organization lawyers in motion in 2026.

Four dated drivers. Each one changes who a firm or an organization can hire before the next return is due.

Public Law 119-21 rewrote the college endowment tax. The Act was signed on 4 July 2025. Section 70415 replaces section 4968. For taxable years beginning after 31 December 2025, an applicable educational institution pays a tax equal to the applicable percentage of net investment income: 1.4 percent when the student-adjusted endowment is at least $500,000 and not over $750,000; 4 percent when it is over $750,000 and not over $2,000,000; and 8 percent when it is over $2,000,000. The institution must have had at least 3,000 tuition-paying students during the preceding taxable year, more than 50 percent of those students located in the United States, and it must not be a state college or university described in the first sentence of section 511(a)(2)(B).

Student-adjusted endowment is the fair market value of assets, measured at the end of the preceding year, other than assets used directly in the exempt purpose, divided by the number of students. That student count is the daily average of full-time students, with part-time students on a full-time equivalent basis. Assets and net investment income of a related organization are generally treated as the institution’s, with two limits: an amount is counted for only one institution, and assets that are not intended or available for the institution are left out unless the organization is controlled by the institution or is a section 509(a)(3) supporting organization. Net investment income follows rules similar to section 4940(c), and two items that regulations had kept out are pulled back in: interest on a student loan made by the institution or a related organization, and federally subsidized royalty income from intellectual property developed with federal funds. Section 6033(o), added by the same section of the Act, requires the institution to report both the tuition-paying student count and the student count used in the endowment fraction. The Secretary must prescribe anti-avoidance guidance, including guidance on restructuring endowment funds. That is counsel work for returns covering years that begin in 2026. It is why a corporate tax associate is the wrong shortlist for a university tax counsel seat. The statute is 26 U.S.C. § 4968, as amended by Public Law 119-21.

Section 4960 now reaches past the five highest-paid employees. Section 70416 of the same Act rewrites section 4960(c)(2). For taxable years beginning after 31 December 2025, a covered employee is any employee of an applicable tax-exempt organization, or of a predecessor, and any former employee who was an employee during any taxable year beginning after 31 December 2016. The tax itself is the pre-existing excise: the rate of tax under section 11, which is 21 percent, on remuneration in excess of $1 million and on excess parachute payments (26 U.S.C. § 4960; 26 U.S.C. § 11). A hospital, a university, a foundation, and a large association each have to re-identify who is covered before the first return for a year that begins in 2026. That work sits with exempt-organization counsel, beside the compensation committee. It is a reason general counsel seats at those organizations are being rewritten in 2026, not a reason to hire a benefits lawyer who has never prepared the Form 990.

Social-welfare organizations still have a notice clock, separate from a determination. In fiscal 2025, Table 2-5 records 3,260 Forms 8976 in the notices-of-intent column, 3,231 acknowledgments, and 393 rejections. The notes say acknowledgments and rejections may include notices received in the prior fiscal year, and that the total includes notices not yet acknowledged or rejected, so the three figures are not a single-year identity. An acknowledgment of Form 8976 is not a determination of exemption. An organization that wants a determination letter still files Form 1024-A. On the master file, recognized section 501(c)(4) organizations numbered 69,617 and section 501(c)(6) business leagues numbered 57,916 (Table 2-6). Lobbying limits, political-activity limits, and the 60-day notice under section 506 are three different interviews. Washington is where association legal departments concentrate, which is why tax recruiters in Washington sit next to this page.

Hospitals and private foundations are different products inside the 501(c)(3) count. A hospital that relies on section 501(c)(3) also lives under section 501(r): a community health needs assessment, a financial assistance policy, and limits on billing. A health-system lawyer whose file is physician contracting is recruited with the healthcare practice. The lawyer who defends exemption and prepares Form 990, Schedule H, is this search. Private foundations are inside the 1,596,231 section 501(c)(3) organizations. Table 2-6 does not publish a separate foundation census. Their excise regime is still its own product: the tax on net investment income under section 4940, self-dealing under 4941, the distribution requirement under 4942, excess business holdings under 4943, jeopardizing investments under 4944, and taxable expenditures under 4945. Those taxes are reported on Form 4720, of which the IRS examined 188 in fiscal 2025. A public-charity counsel who has never prepared a Form 990-PF is a different hire. Universities that will compute section 4968 for a year beginning after 31 December 2025 concentrate in Boston and New York, on tax recruiters in Boston and tax recruiters in New York.

03 Who hires

Five buyers. They do not want the same lawyer.

The audience is a hiring partner, a general counsel, or a board hiring its first counsel. Candidates use the same map to see which seat is actually open.

Law-firm exempt-organization groups. The buyer is a practice head replacing a partner, adding a counsel who can sign a determination and a Form 990, or hiring an associate who has already lived inside a private-foundation or hospital exemption file. The test is the docket. A corporate tax partner who has attended one scholarship-approval call is not an exempt-organization lateral. Conflicts decide whether a conversation can start: the lawyer’s current charities, and the firm’s existing board and donor relationships. Partner searches of this kind run through partner recruiting.

Private colleges and universities. The buyer is a sitting general counsel, or a president and board hiring a first general counsel, because section 4968 applies to taxable years beginning after 31 December 2025. The brief is the student-adjusted endowment, related-organization assets, student-loan interest, federally subsidized royalties, and the section 6033(o) student-count report. Compensation for the lawyer is not the section 4960 threshold and not the chief executive’s Form 990 figure. It is discussed with the general counsel salary page. A first general counsel, where the institution has never had one, is first general counsel search.

Hospitals and health systems. The buyer is the general counsel of a system, or a deputy whose portfolio is exemption, section 501(r), and section 4960 compensation. The reporting line is the chief legal officer. Physician-enterprise deals and medical-staff bylaws stay with healthcare. Mixing them onto one requisition produces a shortlist that can do neither file well. Where a legal department already exists, the path is in-house counsel recruiting.

Private foundations. The buyer is a foundation president hiring a first counsel, or a law firm hiring the lawyer who runs sections 4940 through 4945. At a small foundation the grant policy and the excise computation are often the same person. At a large foundation they are two people, and the second may sit in finance. Writing one job description for both is how the search stalls. The in-house version of a first counsel seat is the same first general counsel path, scoped to the excise regime rather than to a commercial contract book.

Associations and social-welfare organizations. The buyer is the general counsel of a section 501(c)(6) or 501(c)(4), often in Washington, where the membership, the lobbying disclosures, and the Form 8976 notice sit in one legal department. Fiscal 2025 left 57,916 recognized business leagues and 69,617 recognized social-welfare organizations on the master file. The nonprofit and tax-exempt speciality is the governance and grants version of those same organizations. Use that page when the brief is the board and the grant. Use this page when the brief is the Code. Candidates comparing the two should read both before sending a CV through the confidential submission.

04 Compensation

Four public figures. None of them is an exempt-organization counsel median.

Use the figure that matches the desk. A board that copies the chief executive’s Form 990 pay onto a general counsel requisition is pricing a different job.

Candid released its 2024 Nonprofit Compensation Report on 8 August 2024. Median chief executive compensation was $132,077 in fiscal year 2022, up from $118,541 in 2018. The report draws on 209,655 observations from 128,238 tax-exempt organizations filing Forms 990 and 990-EZ. That median is the chief executive. It is the number a board already uses for the president. It is the wrong number for the lawyer. Candid sells a separate cut for the top legal position. The 8 August 2024 release does not print a national legal-position median, and this page does not invent one.

The statutory figure counsel will actually compute is section 4960. Remuneration above $1 million, and excess parachute payments, are taxed at the rate under section 11, which is 21 percent. For taxable years beginning after 31 December 2025 the covered-employee definition is any employee or qualifying former employee, including predecessor organizations, under Public Law 119-21, section 70416. The $1 million is a tax threshold on the organization’s return. It is not a salary survey, and it is not an offer to the lawyer who prepares that return.

At firms that matched the June 2026 scale, Bloomberg Law reported on 2 June 2026 a base of $235,000 to $455,000, effective 1 July 2026. That ladder is what an associate earns at a matching firm. It is not an exempt-organization differential, and it is not what a university pays a deputy general counsel. The class-year table, and the reason a tax specialty does not have its own printed dollar, is on the 2026 tax attorney salary page. ACC’s 16 September 2025 Law Department Compensation Survey puts in-house Attorney median base at $148,000 and Senior Attorney median base at $201,000. Tax appears in that survey as a specialty rank. Exempt organizations do not appear as their own dollar. Quoting those title medians as nonprofit-counsel pay overstates the document. General counsel cash, as a title across employers, is on the general counsel salary page.

Company and firm searches are retained only. The fee is 25–30% of the hire’s total first-year compensation. Thirty percent of that fee is paid as a retainer at engagement and kept if the client cancels. A general counsel or chief legal officer search carries a 12-month replacement window. Other in-house searches carry 6 months. A conversation about a specific seat starts at a confidential briefing or contact.

05 Searches

The exempt-organization searches closed from October 2023 through September 2026.

These counts are the exempt-organization book only. They are not the firm-wide general counsel total, and they are not the interim book.

From October 2023 through September 2026, Sartori & Partners closed 14 tax-exempt-organization searches: 8 for law firms and 6 for organizations. Of those 8 firm searches, 5 were partner and 3 were associate or counsel. Of the 6 organization searches, 4 were general counsel or deputy general counsel and 2 were tax counsel. 12 of the 14 ended with an accepted offer. The median time to a shortlist was 21 days. The median time to an accepted offer was 13 weeks.

Across general counsel and chief legal officer searches, the shortlist is 24 days and the median to an accepted offer is 11 weeks, on 52 GC and CLO searches since 2017. That series is the firm-wide general counsel book. The 14 searches here are a practice cut for October 2023 through September 2026. The 8 law-firm files sit outside those 38. The 6 organization files can sit inside them. Adding 14 to 38 counts the same in-house file twice.

One of the 6 organization files, and one of the 4 general counsel or deputy files: a private research university in Boston hired its first general counsel in 12 weeks, with a shortlist on day 19. The brief was a lawyer who had prepared a Form 990 and advised a board on section 4960, reporting to the president, with outside exempt-organization counsel remaining on the endowment computation for the first year. Week 12 is one week faster than the 13-week median of this book, and one week slower than the 11-week median of the 52 general counsel searches. Day 19 is two days faster than the 21-day median of this book. The replacement window on a general counsel search is 12 months.

The shortlist was counsel who had already prepared a Form 990 and briefed a board on section 4960, not corporate tax lawyers reading the exemption rules for the first time. We hired our first general counsel in 12 weeks.

The other 2 of the 14 did not end in an accepted offer. In both, the requisition asked one person to prepare the Form 990, compute the section 4968 tax, and serve as board secretary. The shortlist, delivered on the 21-day median, showed those were different lawyers. That scoping problem is the line between this page and the nonprofit and tax-exempt speciality. Interim cover, when a board needs someone in the chair before a permanent general counsel starts, is a separate book from these 14 retained searches: 60+ interim and fractional engagements, with a median of 7 days from first call to start. That path is interim legal talent.

06 Within tax

Where this search sits beside tax and nonprofit.

Exempt-organization tax is one instruction. Planning, city markets, and governance are separate pages.

All tax recruitment · Tax planning and controversy · Nonprofit · Nonprofit and tax-exempt · Tax recruiters in Washington · Tax recruiters in Boston · Tax recruiters in New York

Use the planning-and-controversy page when the hire must write a corporate structure and then defend it on exam. Use the nonprofit pages when the hire must run a board, a grant program, or a charitable registration. Use this page when the structure is already exempt, or needs to become exempt, and the work is the application, the Form 990, the private-foundation excises, unrelated business income, or the section 4968 and 4960 computations for a year beginning after 31 December 2025. Washington covers associations. Boston and New York cover universities, hospitals, and foundations. Compensation detail stays on the tax attorney salary page and the general counsel salary page.

09 Sources

The documents behind the dated figures.

Tax-exempt organizations recruitment — common questions

What does a tax-exempt organizations recruiter search for?

A tax-exempt organizations recruiter fills qualification, Form 990, private-foundation, unrelated-business-income, and excise-tax seats, for a law firm or an exempt organization. In fiscal 2025 the IRS recognized 1,916,367 section 501(c) organizations and closed 145,202 applications for tax-exempt status, approving 88.6 percent (IRS Data Book, April 2026, Tables 2-6 and 2-4). It examined 889 Forms 990, 990-EZ, and 990-N in the same year (Table 3-5). From October 2023 through September 2026 Sartori & Partners closed 14 tax-exempt-organization searches.

Who hires tax-exempt organization lawyers?

Five buyers. Law-firm exempt-organization groups. Private colleges facing the section 4968 rates for years beginning after 31 December 2025. Hospitals whose exemption depends on section 501(r) as well as 501(c)(3). Private foundations running sections 4940 through 4945. And associations under sections 501(c)(4) and 501(c)(6). Of the 14 searches closed from October 2023 through September 2026, 8 were for law firms and 6 were for organizations. A private research university in Boston hired its first general counsel in 12 weeks.

How long does a tax-exempt organization search take?

On the 14 tax-exempt-organization searches closed from October 2023 through September 2026, the median time to a shortlist was 21 days and the median time to an accepted offer was 13 weeks. 12 of 14 ended with an accepted offer. The Boston first-general-counsel hire reached a shortlist on day 19 and an accepted offer in week 12. Firm-wide, general counsel and chief legal officer searches run to a 24-day shortlist and an 11-week median, on 52 searches. Searches are retained only. The fee is 25–30% of first-year total compensation, and 30% of that fee is the retainer.

What do tax-exempt organization lawyers earn in 2026?

There is no published national median for general counsel of a tax-exempt organization. Candid’s report of 8 August 2024 puts median chief executive pay at $132,077 for fiscal 2022, from Forms 990 and 990-EZ. That is the president, not the lawyer. Section 4960 taxes remuneration above $1 million at the section 11 rate of 21 percent. At firms that matched the June 2026 scale, Bloomberg Law reported on 2 June 2026 a base of $235,000 to $455,000. The bands are on the tax attorney salary page and the general counsel salary page.

How is this search different from nonprofit recruiting?

Nonprofit recruiting covers governance, grants, and the operating culture of the sector, on the nonprofit practice and the nonprofit and tax-exempt speciality. This search is the Internal Revenue Code: qualification, the information return, unrelated business income, private-foundation excise taxes, and the endowment and excess-compensation taxes in Public Law 119-21. Of 8 law-firm searches in the October 2023–September 2026 window, 5 were partner and 3 were associate or counsel.

Tax-exempt organizations

An exempt-organization hire starts with the return, not a title.

Tell us whether the seat is a determination, a Form 990, a private foundation, a hospital, or a section 4968 computation, and whether it sits in a firm or under a board. We will say if we should run it. Retained only.