Brad assists private foundations and public charities with navigating complex tax regulations and procedures, including receipt and disposition of complex charitable gifts and participation in innovative forms of impactful philanthropy.

Practice Focus

Brad assists private foundations and public charities with navigating complex tax regulations and procedures, including receipt and disposition of complex charitable gifts and participation in innovative forms of impactful philanthropy. He also advises on governance matters, guiding charities and other nonprofits through formation, reorganizations, mergers, affiliations, and dissolutions.

Additionally, Brad advises private clients on securing their long-term goals related to preserving and protecting their wealth and executing their philanthropic endeavors. He counsels families on structured charitable giving, estate planning and lifetime gifting strategies as well as coordination of tax and legal requirements for cross-border families. Brad was recognized as a Notable Practitioner assisting US and international high net worth families with philanthropy and trusts and estates planning in Chamber’s High Net Worth guide.

Brad has 15 years of experience in private practice with national firms and also previously worked as a tax law specialist with the Exempt Organizations Division of the IRS in Washington, D.C. Before his legal career, Brad obtained advanced degrees in English language and literature and taught medieval literature at universities in the United Kingdom, Japan, and the United States.

Brad is also a Senior Vice President of Hemenway Trust Company, a New Hampshire based private fiduciary firm.

Representative Clients

  • Helping large and small nonprofits navigate business operations during the COVID-19 crisis, including applying for the Paycheck Protection Program (PPP) and loan forgiveness, as well as other elements of the CARES Act, the use of endowment funds and remote meetings and governance issues.
  • Negotiated complex integration, including extensive coordination with local and state governmental organizations, of cultural nonprofit with larger charity to ensure the financial stability and enhance the programmatic offerings for both organizations.
  • Procured abatement from IRS of $10M in tax assessments and penalties against private foundation.
  • Assisted university in negotiating, accepting and managing complex charitable gifts, including charitable remainder trusts, gift annuities, and gifts of interests in real estate and closely-held businesses.
  • Advised on administration of endowment and restricted funds, including appropriations, terminations, and cy pres or deviation actions.
  • Provided tax analysis to university establishing commercialization fund to help transition university research to the marketplace.
  • Represented educational organizations in spin-off of program into separate non-profit and subsequent merger.
  • Advised tax-exempt organizations on issues pertaining to partnerships with for-profit entities and unrelated business income tax, including the tax on parking and transportation benefits.
  • Established and procured recognition of tax-exempt status for organization supporting firefighters.
  • Helped establish first pay-for-success bond to include donor-advised funds as investors
  • Developed donor-advised fund program for community foundation
  • Negotiated first non-judicial settlement agreement involving charitable organizations and the Office of the Attorney General of the Commonwealth of Massachusetts
  • Negotiated terms of endowment fund with City of Boston for maintenance of city park
  • Assisted family with highly appreciated post-IPO stock dispose of stock in tax efficient manner, including combination of gifts to charitable remainder unitrusts, private foundations, and public charities
  • Advised on cross-border estate and trust planning for family with connections in the U.S., Europe, and the Middle East

Related News & Resources

Brad Bedingfield to Present at MCLE's "Representing Nonprofits: BasicsPlus!" on June 15, 2022
June 15, 2022
Firm News
Listen to Brad Bedingfield ACTEC Podcast “The Accidental Private Foundation: Non-Exempt Charitable Trusts Under Section 4947”
May 24, 2022
Brad Bedingfield and Eleanor Evans to Present “Updating Governing Documents" at the ECCF Institute for Trustees (Virtual)
May 24, 2022
“Philanthropists, charities, and socially minded companies are seeking increasingly innovative ways to leverage the impact of social investments. Effective solutions require careful balancing of individual investment goals, community impact, and legal and governmental constraints. Helping clients align these disparate concerns to find new ways to further their personal and charitable goals is incredibly rewarding.”
— Brad Bedingfield's Comments on Social Impact Investing