IRS Opinions 'Open Door' for Tribal Philanthropy

By JENNIFER MOORE and GRANT WILLIAMS

The Internal Revenue Service has given American Indian philanthropy a lift in two opinions that it issued to an organization that works with tribes.

In the first opinion, the I.R.S. said that an organization created by a tribe under the tribe's law on corporations could qualify as a foundation or a charity under Section 501(c)(3) of the Internal Revenue Code. That has not always been clear, the I.R.S. noted. "The question was whether the tribal government had