Janice Rodgers concentrated her practice on representing and advising not-for-profit organizations, including private and public foundations, charitable and educational institutions, and other tax-exempt entities. She also had experience in advising both individuals and institutions on charitable giving, including charitable remainder trusts, charitable lead trusts, direct gifts, and tax planning for long-term charitable gift programs. She was a frequent speaker on topics such as permissible lobbying and political activity of tax-exempt organizations; private foundation rules; not-for-profit organization investment standards and procedures; ethical, legal, and governance principles and best practices for not-for-profits; and director and officer responsibilities, liabilities, and insurance. Ms. Rodgers' most recent experience included:

• Advised private foundations (corporate, family, and independent) concerning grants, including to international organizations, coalitions, non-501(c)(3) organizations, and for-profit entities and for scholarships; and appropriate due diligence, documentation, and record-keeping.


• Advised private foundations concerning program-related investments, including loans and guarantees for environmental conservation and other purposes and direct investments in for-profit entities for environmental and economic development purposes.


• Advised organizations concerning compliance with tax laws, including private foundation rules on self-dealing, minimum distribution requirements, excess business holdings, jeopardizing investments, lobbying, political activity, grants to individuals, and expenditure responsibility; intermediate sanctions for excess benefit transactions; and unrelated business taxable income; and maintaining tax-exempt, public charity, or private operating foundation status.


• Advised organizations regarding the attributes of different organizational structures, including trust or corporation, and tax status, including private foundation, public charity, private operating foundation, and church or school, and analysis of the appropriateness for a particular organization.


• Advised donors on alternative structures and vehicles for their charitable giving, including private foundations, donor-advised funds, supporting organizations, and charitable lead or charitable remainder trusts.


• Advised institutions regarding receipt and negotiation of, and agreements regarding, various forms of charitable donations, including real estate, stock, artwork, and gifts through estates, trusts, charitable gift annuities, retirement plans, and life insurance.


• Created new organizations and secured federal income and state and local sales and property tax exemptions.


• Restructured not-for-profit organizations, ranging from amendments to articles of incorporation and bylaws, to mergers, liquidations, or conversion from trust to corporate form, to changing tax status.


• Advised hospitals, colleges, and other institutions regarding governance issues, including compensation and audit committee structures and functions, satisfaction of board member fiduciary duties, conflict of interest issues and policies, and endowment policies and procedures.


• Advised organizations concerning investment policies and procedures and reviewed management contracts and investment partnerships and other structures.


• Prepared and reviewed tax returns (including Forms 990, 990-PF, and 990-T) and other governmental filings.


• Represented organizations in seeking rulings from, negotiating tax liability with, and audits by, the IRS.


• Coordinated the services of other attorneys (both inside and outside Quarles & Brady) to not-for-profit clients.