The Mayo Clinic is famous both for its medical care and patient education. In fact, its website is often cited by news organizations and others when reporting on medical stories; it is known for its accuracy and excellence. When the IRS determined that the Mayo Clinic was not entitled to its refund claim for substantial Unrelated Business Income Tax (UBIT), which the Mayo Clinic claimed based on its educational activities, the Clinic took action. Here’s the whole story, and what it means for nonprofits.
What Is Unrelated Business Income Tax (UBIT?)
UBIT stands for Unrelated Business Income Tax. It’s a tax imposed on income that tax-exempt organizations such as nonprofits earn from activities not substantially related to their core exempt purpose. The Mayo Clinic claimed education as an activity substantially related to its core purpose.
The IRS Said No
The IRS felt differently, however. They assessed $11,501,621 in unpaid acquisition indebtedness UBIT for tax years 2003, 2005-2007, and 2010-2012. This amount was based on the acquisition indebtedness of property held by the Mayo Clinic. The property produced income. While the Mayo Clinic paid the debt, they initiated the request for a refund in 2016, which brings us to the current ruling.
Why did the IRS question the Mayo Clinic’s report? The IRS concluded that for the years in question, the Mayo Clinic did not meet the definition of a § 170(b)(1)(A)(ii) qualified organization as defined in Treasury Regulation § 1.170A-9(c)(1). To sum up the regulation, if the Mayo Clinic claimed education, it must be formal instructional activities, not merely incidental educational activities. Given that the clinic’s primary purpose is to provide medical services, at first, this seemed reasonable.
The Case Winds Its Way Through the Courts
The Mayo Clinic contested these findings, and as the case wound its way through the court system, various courts interpreted the IRS rulings differently. At issue was whether the Mayo Clinic’s educational activities were in addition to or inexorably intertwined with its medical services.
After much debate, the final district court found that “primary” purpose in this case means “substantial” and that the Mayo Clinic did meet the definition of education in the context of a substantial portion of its activities. Equally as important, its educational context was not “non-essential” but deemed an essential part of its primary mission. Given this, the court ruled that the Mayo Clinic was entitled to a full refund. The government is appealing this decision.
Context for Nonprofits
This case highlights several nuances in assessing a nonprofit’s educational purpose. To government entities such as the IRS, it means that education must be the primary purpose of the nonprofit, such as the activities of a college, school, or other institution of learning. However, many nonprofits, such as the Mayo Clinic, engage in significant educational activities with their constituents, but primarily engage in other services, such as medical care.
At issue in the case is whether or not such activities count as “substantial” enough to justify the requested refunds, or whether the organization’s primary purpose must be education in order to qualify under the IRS ruling.
Why This Matters
This ruling sets a powerful precedent for nonprofit organizations with hybrid missions. It signals that substantial commercial activities do not automatically disqualify an institution from being considered educational, as long as those activities are integrated with and serve the educational purpose.
For CPAs, nonprofit advisors, and academic institutions, the case offers a roadmap for navigating UBIT exemptions. It emphasizes the importance of demonstrating how various functions support a unified, exempt purpose.
Final Thoughts
The Mayo Clinic case is more than a tax dispute. It’s a reaffirmation of how education can be effectively integrated into complex, real-world operations. It challenges narrow definitions and opens the door for more nuanced evaluations of nonprofit missions. For organizations walking the line between service and instruction, this decision offers clarity with context.
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