What is the reason private clubs get to be tax-exempt?
How much do private clubs get paid when they hold a charity tournament? Isn't that the opposite of charity?
Ok, on the understanding that this isn't tax advice, under section 501(c)(7) of the internal revenue code, certain organizations organized for social, but not business, purposes are exempt from federal income tax. The theory behind this is that the organization is simply the holder of a pool of money contributed by individuals to socialize, and it isn't right to tax a group of people who, rather than spending money as individuals for social purposes, i.e., rent out a park baseball field and have games every saturday, pool their money together, and use that pool of money for social purposes, i.e., to own and operate a golf course. If an individual runs a league, and collects fees from participants to use for expenses, he's not taxed on the fees he collects, and the club is the sam.
The organization itself isn't a business since in theory all of its revenue comes from the individual members. That's why the IRS has rules to ensure that the club is organized for social purposes or to make a profit. That's also why outside income is limited, because otherwise outsiders would be subsidizing the member's activities, and that would be conducting a business designed to earn profits, with the profits used to defray costs of the members.
To make things easy on outside income, the IRS has a safe harbor, which allows social clubs to get 15% of their gross revenue from nonmember activities. The IRS also is ok with occasional big dollar events like tournaments, but if you hold a tournament every year, and use that money to support the club, you'd probably lose your exemption (regardless, the club still has to pay tax on the profits from the occasional big event, even if it is tax exempt).
I know Sean thinks that there can be a lot of nonmember play and still stay below the 15%, but if you hold monday outings and some banquets not sponsored by a member, it isn't that tough to get close to the number (initiation fees don't count in determining gross revenue). Also, there is something funny about a member spending a big number per round in dues and other costs, and letting nonmembers play for a lot less.