Sharon C. Lincoln

  • Associate
  • Boston
  • 617 832 1287 direct
  • 617 832 7000 fax

Sharon Lincoln advises nonprofit entities in regard to all issues related to their tax-exempt status, including formation, funding, governance, regulatory compliance, restructuring, international grant making, lobbying, unrelated income and mergers and acquisitions. In addition, she assists clients in matters directly involving the Internal Revenue Service and the Massachusetts Department of Revenue, including audits, appeals and ruling requests. A variety of clients have turned to Sharon for guidance regarding federal and state tax matters in general, as well.

Prior to joining Foley Hoag, Sharon practiced in the tax and benefits department of another national law firm.

Bars and Court Admissions

  • Massachusetts

Representative Experience

The following is a brief summary of Sharon's experience and accomplishments:

  • Advised several national charitable organizations regarding the federal tax laws regulating the participation of such charitable organizations in lobbying activities, including the expenditure test under Code section 501(h)

  • Assisted several different charities with structuring relationships (joint ventures, partnerships, etc.) with non-charitable entities

  • Provided a large tax-exempt healthcare organization with guidance regarding the excess benefit rules as they applied to compensation paid to the organization’s executives

  • Assisted a national microfinance organization with structuring matters

  • Managed the IRS audit of a major university

  • Provided specific guidance regarding maintaining tax-exempt status to several national charities that were undergoing (or considering) significant restructuring

  • Assisted a large tax-exempt healthcare organization with tax aspects related to making a renewable energy investment

  • Obtained private letter rulings for two different clients regarding Code section 355 spin-offs

  • Managed the DOR sales tax audit for a Massachusetts technology company

  • Assisted several clients engaged in renewable energy technologies to understand the energy and production tax credits under Code section 45 and 48

professional / civic involvement

  • American Bar Association, Member of the ABA Tax Section’s State and Local Tax executive committee and co-chair of the SALT subcommittee on Tax-Exempt Organizations
  • Boston Bar Association, Member of the Tax-Exempt Organization Section's Steering Committee
  • Presented “Executive Compensation: An Overview of the Excess Benefit Rules” at the Boston Bar Association (February 2011)
  • Participated in the American Bar Association Tax Section’s task force on the alternative minimum tax and helped to draft the final report (2003-2004)