Nonprofit Law Prof Blog

Happy Fourth of July from the Nonprofit Law Prof Blog!

From the editors of the Nonprofit Law Prof Blog, we wish you all a safe and happy Fourth of July! 

At this time, I am reading about the history of charity and philanthropy in America, and the connections between them and civility.  Whether you are at the beach or sitting in your favorite chair at home, I highly recommend to you, Charity, Philanthropy, and Civility in American History, edited by Lawrence J. Friedman and Mark D. McGarvie.  New York:  Cambridge University Press, 2003.  This book provides an interesting survey of charity and philanthropy through the lenses of scholarly historians who attempt to track the evolution of these ideals and practices through time and movements -- gender, race and national origin.

AMT

Providence RI to Study Nonprofits, Possible PILOTs

Another example of the push by local governments to "tax" tax-exempt nonprofits comes from Rhode Island.  The Providence Journal reports that the city council of Providence agreed Thursday to establish a commission to study the potential for getting revenue from local tax-exempt entities.  Apparently, the Rhode Island state legislature is considering measures to give cities the ability to tax nonprofit hospitals and colleges that currently are tax-exempt. 

A proposal to assess a “student impact fee” on private colleges and universities is currently before the full state House of Representatives, and another proposal is pending before a House committee.  Another bill would authorize municipalities to collect a fee in lieu of taxes from nonprofit entities that own properties assessed at $20 million or more. That proposed fee has not yet been voted on by the House Finance Committee.

One wonders whether, particularly in cities on the east coast (Boston is another leader in this area), we are reaching some sort of "tipping point" where nonprofits will no longer be exempt, or perhaps only partially exempt, from local property taxes.

JDC

Should Wikipedia Not be Tax Exempt? Its British Cousin is Not!

Wikipedia describes itself as a "free encyclopedia that anyone can edit."  It has an .org suffix, presumably confirming its tax exempt status (or at least strongly suggesting it, but I presume it is tax exempt without checking, besides its free and I don't see any advertisement on its site).  No doubt it is "educational" in the Big Mama Rag sense of the word and therefore deserving of tax exemption under IRC 501(c)(3).  But our UK cousins have apparently determined that the UK arm, known as Wikimedia UK is not "educational" because the mere dissemination of ideas "is not in itself a charitable object unless it is combined with teaching or education."  Balderdash, I say!  By the way, this astonishing tidbit was reported to us by the very informative International Journal of Civil Society Newsletter (June 2009)..   According to the online Charity Finance"  (quoting the HMRC)::

In its guidance The Advancement of Education for the Public Benefit, the Charity Commission says organisations must provide evidence of educational benefit and states: “A modern example might be a ‘wiki’ site which might contain information about historical events but, if this information is not verified in any way, it would not be accepted as having education merit or value without positive evidence.”

To see a full copy of the UK determination letter denying tax exemption, go here.  The key language is this:

The production of an encyclopaedia is not the charitable advancement of of education and has not been accepted as such in law. In Re Shaw [1957] 1 WLR 729 Mr Justice Harman said "If the object be the mere increase of knowledge it is not in itself a charitable object unless it is combined with teaching or education". Nor is the support the Wikipedia, the stated primary purpose of Wiki UK Ltd, a charitable purpose.
.

Here is what the Wikimedia UK Secretary told its Board:

Their objection goes to the heart of what we have been established to do. On the surface, it does not appear that any different wording in our constitution or correspondence would have given us a different outcome. Nonetheless, the legal issues may be arguable - our job is not just to produce content in isolation, but also to spread that knowledge and make it accessible to all. I should imagine this will come down to the finer points of law, and it is probably best to engage a lawyer at this stage when we appeal. If we had applied to the Charity Commission before HMRC the application would have been considered by different lawyers but the same law would apply. Therefore, it is likely that we would have come up against the same problem. I'm contacting the Foundation to ask them if they are aware of any lawyers familiar with UK law who could help us pro-bono on this. I'm also sending a note to our MP to thank him for his help in speeding this up: although it is disappointed to get this response, it is better to get it now that in 3 or 6 months' time. In the meantime, we should probably stop referring to ourselves as a "charity" or an "exempt charity". Before receiving this letter it was reasonable for us to do this as that was our honest view. Now we know there is some disagreement over this, I suggest we should describe ourselves as a "not-for-profit" instead. Whilst we can still get Gift Aid declarations (HMRC have previously confirmed this was ok) we should probably add a caveat on the form explaining that our charitable status is contested.

Me thinks our brethren have this completely wrong.  The dessimination of uncensored, raw and un-commented upon information (nevermind that the dessiminator cannot possibly dessiminate without at least implicit comment, even the organization of information is a subjective comment) is, if that is even possible, as valuable or more as censored, edited, and commented upon information.  Stupid is as stupid does.

dkj

Male Nonprofit CEO's Make More than Female Nonprofit CEO's another Study Finds

A Study completed by the Rollins Philanthropy and Nonprofit Leadership Center confirms that "the man"  (pictured above in recline) is still in charge.  According to the 200 page report, summarized online but made available in full for the tidy sum of $139.00, "On average male CEO/executive director pay is $110,962 per year; for women, the average executive director pay is $80,897 per year. A relatively greater number of men are found in the CEO/executive director positions of the largest organizations, which tend to pay higher wages."  Thats nearly a 30% discrepancy, according to this article in the Chronicle of Philanthropy.

dkj

Obama to Search for "Most Promising" Nonprofits in America: A Reason to Use the Tax Code instead of Direct Appropriations to Fund Charities

On June 30, 2009, according to the Chronicle of Philanthropy, the White House announced that administrative officials will search for "worthy" charitable recipients of a $50 million fund designed to help charities expand innovative social projects:

Surrounded by more than 100 philanthropic leaders in the East Room of the White House, Mr. Obama said he was glad there were some “deep pockets” in the audience, as he also wants corporations and foundations to chip in to help the administration create a “new kind of partnership between government and the nonprofit sector.”  Our nonprofits can provide the solutions,” he said. “Our government can rigorously evaluate these solutions and invest limited taxpayer dollars in ones that work.” But, he said, private donors are needed to provide seed capital, matching funds, and strategic advice.

The Social Innovation Fund, described in flowerly optimistic language on the White House Blog, was part of the Edward M. Kennedy Serve America Act (signing video of signing ceremony and link to million page act) though Congress has yet to appropriate the money.  Perhaps this is the charitable version of an "unfunded mandate."  Still, I don't want to be too cynical about the initiative just yet.  But I'd rather hold my applause until the checks are sent.  Who can complain, though, when the government wants to give $50 million to charitable organizations.  Ok, here is food for thought:  The Nonprofit Sector is known as the Independent Sector for a reason.  It is independent and not beholden to either government or business. In an ideal world, it should receive all of its funding from grass roots sources so that it may maintain its independence and indeed, its appareance of independence.  Once the government starts doling out funds in a selective manner to nonprofits selected this administration or that, we should expect that only those charities whose political inclinations are in line with the doler-outers will receive funds.  Will the Obama administration, for example, direct funds to the conservative Heritage Foundation?  Probably not; if I were in charge the public interest law firm that challenges all sorts of affirmative action efforts -- the Center for Law and Justice, I think is their misnomer --  would not get a red cent!  Hey, I am just being honest.  I'd find some way to label them "unworthy".  See, that's the problem with what seems like a good idea.  It has to be administered by people on an official level.  In this case, it seems innocuous enough but wait until a liberal think tank gets a grant but a conservative one does not.  Or in some future administration, a conservative group gets funded but a liberal one doesn't.  Good intentions don't always lead to good results.  The point is, if nonprofits ought not finacially support any particular governmental philosophy, perhaps the opposite is true.  That's my point of view.

dkj

The Pocantico Declaration: Forming a Nonprofit Investigative Reporting Network

We have blogged several times recently about the possibility of using the nonprofit form for failing newspapers (see prior posts here, here, here and here).  Efforts to create a broader nonprofit news-gathering infrastructure got a boost this week when representatives of some 25 nonprofit news-gathering organizations and journalism schools completed a three-day conference on the state of investigative journalism and issued The Pocantico Declaration to form a nonprofit investigative news network.  The Declaration sets up a steering committee consisting of Bill Buzenberg, executive director of the Center for Public Integrity; Sandy Close, executive director of the Pacific News Service; Sheila Coronel, director of the Stabile Center for Investigative Journalism at Columbia University; Margaret Engel, executive director of the Alicia Patterson Journalism Foundation; Laura Frank, cofounder of the Rocky Mountain Investigative News Network; Margaret Wolf Freivogel, founding editor of the St. Louis Beacon; Brant Houston, Knight Chair professor in Investigative and Enterprise Reporting at the University of Illinois; Joel Kramer, CEO and Editor of MinnPost; Charles Lewis, founding executive editor of the Investigative Reporting Workshop at American University; Scott Lewis, CEO of voiceofsandiego.org; and Robert Rosenthal, executive director of the Center for Investigative Reporting.  The Declaration says that the steering committee's initial goal is to

seek and obtain sufficient grant funding to develop a plan for sustaining and strengthening nonprofit investigative journalism. The Committee will begin immediately to spearhead the fundraising work for a planning grant and a possible grant for continued editorial project collaboration, including doing major investigative projects, and foster greater administrative and related, “back office” organizational efficiencies. In addition, the Committee will design and construct an Investigative News Network website, and will take full advantage of other emerging technologies to coordinate, curate and showcase the best content of the Network member publishers and its growing, searchable “long tail” archive.

JDC

Two New Studies on Recession's Effects on Charities

Two new studies, one by the Johns Hopkins Listening Post Project and the other by The Bridgespan Group detail the effects of the recession on charities.  As one would expect, the news is mostly grim: the Johns Hopkins study found that 80% of charities reporting financial stress and nearly 40% of the respondents described that stress as "severe."  Theater and orchestra groups appeared particularly pessimistic, with one-third of theater respondents and almost a quarter of orchestras reporting concerns about whether they would continue to exist.

The Bridgespan report, which is an update of a survey first taken in November of 2008, found that the percentage of nonprofit that have laid off employees increased during the six months from the first survey and that more charities were making broad-based program reductions.  More organizations were drawing down on reserves, as well.

Still, some charity leaders see a silver lining.  Forty-five percent of those in the Bridgespan survey were optimistic that their financial position would improve over the coming year, while only 22% thought it would worsen.  And many saw a benefit to paring down services to their core mission - a chance to "refocus" their efforts on what they do best.

JDC

Musings on charitable endowments and reserves

Not very long ago, Senator Chuck Grassley, IA, "put the screws" to big universities for hoarding money in what he believed were "excessive" endowments (see prior blog post here).  But this article in the Washington Post should remind us all that charities are just as vulnerable to economic downturns as any for-profit business, and that having significant reserves to weather these downturns is prudent management.  The article details a study of Washington D.C. area charities and found that a significant percentage had too little (or none at all) in reserves to help weather the current downturn.  Interestingly, the study found that bigger charities were more likely to have insufficient reserves than smaller ones.

So charities clearly need to keep a prudent amount of reserves for weathering bad economic times.  But the other side of this question is when, if ever, does a stash of cash become excessive?  Truth is, I don't know.  Squirreling away huge sums of money for the future, whether we call it a "reserve" or an "endowment" implicates the pros and cons of spending for the charitable needs of the current generation vs. future generations.  Many prominent scholars (e.g., Evelyn Brody at Chicago-Kent; Henry Hansmann of Yale; Michael Klausner of Stanford) have written about this issue, with varying conclusions, though I'd say that the weight of opinion is that there is no really good reason for charities to skew their spending towards future generations and a few foundations have made courageous decisions to spend themselves out of existence rather than conserve resources in order to exist indefinitely.  I'd say that Harvard's endowment is (or at least was) beyond the point of reasonable for the scope of its charitable enterprise, but I don't think there is any good consensus on when a prudent reserve crosses the line to Scrooge McDuck's money bin . . .

JDC

Exempt Charities or . . . vacation spots?

The line between an exempt charity and a commercial business has grown ever murkier in our society.  Nonprofit hospitals offer services and operate much like for-profit counterparts, down to using debt collection agencies for past due bills.  Universities raise tuition, build hotels and "research parks," and race to form research partnerships with for-profit entities while shoveling billions into endowments.  But a recent trio of state exemption cases may best describe the tension between what is a charity and what is a commercial business.  In McDuffie County, Georgia, the local property tax assessors are challenging exemption for Fountain Campground, which claims exemption for some 70 acres of land as a site of religious worship - except that the land appears to be fenced, with posted no-tresspassing signs, and is regularly used as a hunt club.  In the Davenport, Iowa, area, local bars and music clubs are claiming unfair competition from River Music Experience, an exempt charity which offers live music acts in its Redstone Room performing venue.  And in Cape May, New Jersey, an order of nuns is seeking tax exemption for property they claim is a religious retreat: three buildings with 160 rooms overlooking the Atlantic Ocean.  Local officials opined that "some of the retreats sound a lot like vacations."

So when, exactly, is an organization an exempt charity or a hunt club, or a bar with live entertainment, or an ocean vacation spot? If the legendary Blue Note in New York City decided to convert to nonprofit status and offer jazz appreciation classes, would it be a tax-exempt charity?  If Tesla Motors was formed by environmental activists as a nonprofit dedicated to commercializing an all-electric sports car in order to save the environment, would it be a charity?

Food for thought . . . 

JDC

Laid-off editors and reporters from Puerto Rico newspaper start a new one as nonprofit employee cooperative

A group of reporters, editors, and other union members in Puerto Rico have started a newspaper organized as a nonprofit employee cooperative.  They started this paper, called the Daily Sun, after their former employer the San Juan Daily Star closed last summer after almost 50 years.  Reports the Miami Herald: "With its break-even economic model and a mission no greater than to employ people, its managers say Puerto Rico's newest media venture may have discovered a business strategy to keep newspaper journalism alive: no profits."

rak

 

New TE/GE Commissioner Ingram Speaks on Nonprofit Governance

Sarah Hall Ingram, the new commissioner of the IRS TE/GE (Tax-exempt and Government Entities) division of the IRS, spoke on June 23 at Georgetown's Continuing Legal Education program about the IRS role in nonprofit governance. In the speech, Ingram identified four general principles that she believes are essential to good nonprofit governance:

A foundational principle is that the organization should clearly understand and publicly express its mission. This helps assure that the organization provides a public benefit and does not drift away from a charitable purpose. It helps an organization avoid practices that are inconsistent with tax-exempt status.

Equally important is the principle that the organization’s board should be engaged, informed and independent. The board should have real responsibility and authority. It must, for example, be able to implement, in the life of the organization, the rules against inurement and self-dealing.

Another set of key good governance principles are those relating to the proper use and safeguarding of assets. These principles are supported by policies and practices that address executive compensation, that protect against conflicts of interest, and that support independent financial reviews.

Transparency is another key principle. I believe that board decisions should be reflected in minutes, that records supporting decisions should be retained for reasonable periods, that whistleblowers should be protected, and that each year’s Form 990 should be complete, accurate and prepared in good faith.

Ingram insisted that the IRS would not create a "one size fits all" definition of governance, but strongly reaffirmed the IRS's role in governance issues: "Another principle I will follow isthat the IRS has a clear, unambiguous role to play in governance."   While I have some doubts about the extent to which the IRS should be active in governance matters, it is hard to argue with Ingram's view that certain core exemption issues (executive pay, other private inurement, political activity, etc.) do involve governance processes.  It will be interesting to see how the IRS's role in governance evolves under Ingram's leadership.

JDC

ACLU Report: War on Terror Undercuts Liberty of Muslim Donors

Yesterday, we blogged about French President Sarkozy's pledge to outlaw the burqa.  This post prompted two of our readers to send me a report recently issued by the ACLU which concludes that the United States' fight against terrorism has dealt a harsh blow to Muslim charities and interfered with their donors’ religious freedom.   Although we blogged about this report just ten days ago, I shall submit another post about this interesting development.

According to the ACLU report, the government's actions have "created a climate of fear that chills American Muslims’ free and full exercise of their religion through charitable giving, or Zakat, one of the 'five pillars' of Islam and a religious obligation for all observant Muslims."  

The report is based on interviews with more than 100 Muslim community leaders as well as experts on antiterrorism laws and regulations. Although it does not estimate the total decline in donations to Muslim groups, it says a total of nine Islamic charities have closed as a result of government action against them since the Sept. 11 attacks.

A recent New York Times story quoted Maja Freij, chief financial officer at the Arab Community Center for Economic and Social Services, a large Arab-American social services group based in Dearborn, Michigan, as saying, "It’s absolute madness how this policy has been put together and practiced.  It makes you guilty by association, offers no due process and lacks checks and balances.”

Meanwhile, Farhana Khera, executive director of Muslim Advocates, told The Times, “American Muslims with U.S. passports are returning from abroad and being asked about their charitable donations by customs and immigration agents.”

VEJ

Pastor to Flock: Bring Guns to Church

Today's New York Times reports that Ken Pagano, pastor of the New Bethel Church in Louisville, Kentucky, has invited members of his congregation to wear or carry their firearms into the sanctuary tomorrow night to "celebrate our rights as Americans."  The event will form part of Bring-Your-Gun-to-Church Day, which will include a $1 raffle of a handgun, firearms safety lessons and a picnic. 

Pastor Pagano has for some time been a passionate advocate of gun rights.  Two weeks ago, he preached a sermon entitled "God, Guns, Gospel and Geometry."  The Times also reports him as saying, "God and guns were part of the foundation of this country." He also opined that "Not every Christian denomination is pacifist.”  

In Pastor Pagano's church in Louisville, a large wooden cross hangs over the altar; two American flags jut out of side walls.       

Commenting on Pastor Pagano's invitation to his flock, Pam Gersh, a Louisville public relations consultant who helped organize a rally in that city to coincide with the Million Mom March against guns in Washington, said, "This pastor is obviously crossing a line here and saying ‘I can even take my guns to church, and there is nothing you can do about it.’ ”

Pastor Pagano disagrees:

When someone from within the church tells me that being a Christian and having firearms are contradictions, that they’re incompatible with the Gospel — baloney. As soon as you start saying that it’s not something that Christians do, well, guns are just the foil. The issue now is the Gospel. So in a sense, it does become a crusade. Now the Gospel is at stake.

VEJ

Sarkozy Would Outlaw the Burqa

Earlier this week, the New York Times reported that in an address to the French parliament on Monday, French President, Nicolas Sarkozy, gave a withering critique of burqas as an unacceptable symbol of "enslavement."  According to Mr. Sarkozy, there is no room in the French republic for burqas, garments some Muslim women wear to cover their bodies and faces.  

Said Mr. Sarkozy:

The issue of the burqa is not a religious issue. It is a question of freedom and of women’s dignity,  The burqa is not a religious sign. It is a sign of the subjugation, of the submission, of women.

To enthusiastic applause, Mr. Sarkozy stated: “I want to say solemnly that it will not be welcome on our territory.”

I note that France has the largest Muslim population in Western Europe.  Current estimates are that there are approximately five million Muslims living in France.  Yet, traditional Islamic garments have been a divisive issue in that country for several years.  In 2004, for example, France passed legislation prohibiting the wearing of head scarves and conspicuous religious symbols at public schools.  

Meanwhile, Mr. Sarkozy appears to have spoken from both sides of his mouth.  On the one hand, he stated that in France, "the Muslim religion must be respected like other religions."  Yet, he also stated that "the burqa is not welcome in France.  We cannot accept in our country women imprisoned behind bars, cut off from social life, deprived of identity.”

He also gave his support to a cross-party initiative by about 60 legislators who proposed that a parliamentary commission study the burqa and methods to combat its spread.

It would seem that Mr. Sarkozy is likening the wearing of the burqa to "women being imprisoned behind bars, cut off from social life, [and] deprived of identity."  Yet, in my work as a member of the Board of Experts of the International Religious Liberty Association, I have come across many Islamic women in many countries who willingly and gladly wear their burqas.  Sure, the burqa is something some western minds do not understand; but why should the government of France -- or any government, for that matter -- outlaw its use?  What next will President Sarkozy do -- call for Roman Catholic nuns to stop wearing their habits or for ministers of religion like myself to stop wearing our clerical collars or clerical robes in public?    

VEJ

  

NCRP Report: Foundations Hit by Madoff scheme Lacked Adequate Board Size and Diversity

A new report released by the National Committee for Responsive Philanthropy (NCRP) reveals that the majority of the foundations hit hardest by Bernard Madoff's ponzi scheme lacked two things in common: (1) adequate board size, and (2) board diversity.

The report's key findings indicate that:

1. One hundred five (71 percent) of the close to 150 foundations [studied] lost between 30 and 100 percent of their assets due to investments with Madoff.
2. The median board size among these 105 foundations was three, with a range of 0-7 total trustees.
3. A mere 16 (15 percent) of these 105 foundations had boards comprising five or more individuals ... 38 foundations listed only one or two trustees, and 46 foundations listed three of four trustees.
4. Of the 16 foundations with five or more trustees, an analysis of trustee names shows notable homogeneity.

The NCRP recommends that foundations have at least five board members and that these board members have a diverse background. The committee also encourages foundations to have a conflict-of-interest policy and a code of conduct, and to make public demographic information about the board.

VEJ

Analysis: Y.M.C.A., Salvation Army and United Way Have Most Valuable Brands in Nonprofit Field

An analysis by the marketing firm Cone LLC and Intangible Business, a British brand-valuation company, has concluded that the Y.M.C.A. has the most valuable brand in the nonprofit field, followed by the Salvation Army and the United Way of America.

The analysis used financial data, projected growth in revenues and a survey of 1,000 Americans to determine the top 100 most valuable nonprofit brand names among organizations providing social, environmental and animal-related services.

According to the New York Times, nonprofits have for some time now been making efforts to value their brand names.  However, "the new analysis appears to be the first that applies the same method of measuring that value across many different nonprofits." 

The Times continues:

The analysis spotted some interesting things. Environmental groups are the darlings of donors right now and their revenues are among the fastest growing in the sector — but their brand names scored lower values in the Cone research.

“They have spent a lot of time raising awareness of the issues through things like calls to action — put a brick in your toilet, turn out the lights — but not for their brands,” [said Alison DaSilva, executive vice president of Cone].

Conversely, she said, the Make-A-Wish Foundation enjoys widespread recognition, but its revenues do not reflect that. “They can capitalize on the brand recognition to increase revenues,” Ms. DaSilva said.

Rounding up the Top Ten are American Red Cross, Goodwill Industries International, Catholic Charities, Habitat for Humanity International, American Cancer Society, The Arc of the United States, and Boys & Girls Clubs of America.  

VEJ

 

Russian present introduces bill to lower hurdles for nonprofit organizations

The New York Times reports that "President Dmitri A. Medvedev introduced legislation on Wednesday to ease some of the regulatory burdens on nonprofit groups. The current law was approved under Mr. Medvedev’s predecessor, Vladimir V. Putin, who asserted that hat foreign governments were using the groups to meddle in Russia’s affairs." No details yet on the bill's contents. For discussion of the Russia's current regulation of nonprofits, link here and here

rak

International Society for Third Sector Research Issues Call for Papers

The International Society for Third Sector Research (ISTR) has issued a call for contributions.  Here is the text of the CFC.

Call for Contributions

ISTR 9th International Conference

"Facing Crises:Challenges and Opportunities Confronting the Third Sector and Civil Society"

The International Society for Third-Sector Research (ISTR) is pleased to announce that the Call for Contributions for the 9th International Conference is published on our website (www.istr.org/conferences/istanbul/). The conference will be held at Kadir Has University in Istanbul, Turkey, on July 7-10, 2010.

The Call is currently available in English and Spanish; Arabic, Chinese, German and French languages will be added in the very near future.

The deadline for submissions is October 19, 2009.

For more information, see the ISTRwebsite at: www.istr.org/conferences/istanbul/

DAB

A.P. to distribute work from nonprofit groups devoted to investigative journalism

Some for-profit newspapers have reduced the size of their staffs in the face of financial difficulty. In order to fill the gap in investigative reporting, they may soon be relying more heavily on the work of nonprofit organizations devoted to investigative journalism.  As reported in the New York Times, the Associated Press announced that it will distribute work by four such organizations: ProPublica ("journalism in the public interest")  Center for Investigative Reporting ("journalism dedicated to revealing injustice") The Center for Public Integrity ("investigative journalism in the public interest")  The Investigative Reporting Workshop at the American University School of Communication.  (The AP is itself operated as a nonprofit cooperative owned by 1,500 U.S. daily newspaper members, who elect its board of directors.)

rak

A.C.L.U. Report Says Antiterror Fight Undercuts Liberty of Muslim Donors

The American Civil Liberties Union (ACLU) has issued a report that claims that the U.S. government's actions in the fight against terrorism "have created a climate of fear that chills American Muslims’ free and full exercise of their religion through charitable giving, or Zakat, one of the “five pillars” of Islam and a religious obligation for all observant Muslims."  The report, entitled "Blocking Faith, Freezing Charity: Chilling Muslim Charitable Giving in the “War on Terrorism Financing." The New York Times'' Stephanie Strom wrote about the new report on Monday, June 15. 

rak

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