Protecting 501(c)(6) Status

501(c)(6) status exists to recognize that trade and professional associations serve their whole membership's common business interest, not any single member's private benefit, and NANA's position is that the eligibility test built around that principle should not be narrowed to catch legitimate association activity that has qualified for decades. Proposals to tighten (c)(6) eligibility recur every few sessions, usually aimed at closing a narrow abuse elsewhere in the tax code, but drafted broadly enough to sweep in ordinary association programming — a member conference, a certification program, a benchmarking survey sold to members and nonmembers alike. NANA has tracked this file at monitoring status since publishing its Tax-Exempt Status Brief on January 8, 2026, because no single proposal has advanced far enough to require a formal comment response, but Board Secretary Benjamin Oduya, general counsel at the Coalition of Independent Museums, has flagged the recurring pattern to members at each Fall Policy Forum since 2024.

An association that loses or has to restructure around its 501(c)(6) status faces real costs: legal fees to reorganize, a harder fundraising pitch to members who assumed dues were already tax-favored in the way a (c)(6) allows, and in some cases a complete rework of how a certification or conference program is priced and reported. Every NANA member association depends on the same eligibility test, whether it is an 18,000-member civic association or a two-person outfitters council, and a narrower standard would not fall evenly — associations with larger non-dues revenue streams from conferences, credentialing, or data products have more exposure to a test that scrutinizes commercial-feeling activity, even when that activity funds core association work.

NANA is asking Congress and the IRS to leave the current 501(c)(6) common-business-interest test intact, and where a narrower proposal is aimed at a specific abuse, to draft it narrowly enough that it does not also catch ordinary association programming. Member associations are asked to review their own qualifying activities against the Tax-Exempt Status Brief now, while the file is quiet, rather than scrambling once a specific bill advances. Associations with a significant non-dues revenue stream, from conferences, certification, or data and research products, are asked to send NANA's public policy team their current revenue mix, so the association has real member data on hand the next time a narrowing proposal reaches a hearing.