Lowell MILKEN Center
FOR Philanthropy
& Nonprofits

At the Lowell Milken Center for Philanthropy and Nonprofits, our mission is to enhance the understanding of the philanthropy and nonprofit sector and to support it through leading-edge education, thought leadership, and research.  We invite you to explore our commitment to enriching the nonprofit landscape and advancing its impactful work.

The Lowell Milken Center for Philanthropy and Nonprofits is led by a dedicated team of professionals committed to advancing understanding of and promoting solutions for the challenges faced by the nonprofit and philanthropic sector. Our staff bring to the Center a wealth of experience in the sector, deep knowledge of nonprofit law, and great passion for the work of nonprofits and philanthropy.

FOR LAW STUDENTS
Programs

Producing scholarship about the most important issues facing nonprofits as well as their beneficiaries.

FOR LAW STUDENTS
Mission

Producing scholarship about the most important issues facing nonprofits as well as their beneficiaries.

Upcoming
Events

Join us for engaging events, including panel discussions, lectures, and workshops that bring together leaders and experts from diverse areas of the nonprofit and philanthropic sector.

Conference
Thursday, May 15, 2025
Nonprofit Arts: Creative Leadership in Uncertain Times

Join UCLA Law’s Lowell Milken Center for Philanthropy & Nonprofits and the LA County Department of Arts & Culture on Thursday, May 15th, 2025 for a half-day conference to discuss top-of-mind concerns in the nonprofit arts sector.

Tuesday, April 15, 2025
Mary Cruz 25': Launching a Career in Nonprofit Law

Join us to hear from Epstein Program 3L student, Mary Cruz, about breaking into the nonprofit law sector.

*Lunch will be provided.

News + Media

Stay up-to-date with the latest news and developments from the Lowell Milken Center for Philanthropy and Nonprofits.

mission and vision
News + Media
April 27, 2025
Revoking Tax-Exemption for Pursuit of DEI

Aprill's paper "Revoking Tax-Exemption for Pursuit of DEI," makes clear that tax-exempt organizations must prepare now to defend their missions - protecting against what Justice Powell once called "governmental orthodoxy" in shaping community life.

News + Media
April 23, 2025
Can OpenAI Abandon Its Non-Profit “Purpose”?

Can a nonprofit walk away from its purpose? With billions at stake and AGI on the horizon, this article dives into what “purpose” really means under nonprofit law, and why it may not be so easy for OpenAI to abandon it.

News + Media
April 21, 2025
Endowments aren’t blank checks – but universities can rely on them more heavily in turbulent times

Drawing on nonprofit law and historical precedent, Aprill explains the legal frameworks that give institutions flexibility - especially in times of crisis.

News + Media
April 18, 2025
Can the IRS revoke Harvard’s tax-exempt status?

LMPN's Ellen Aprill weighs in on former President Donald Trump's push to challenge the tax-exempt status of Harvard University, a move rooted in allegations of political bias on campus.

News + Media
April 17, 2025
Inside OpenAI's Controversial Plan to Abandon its Nonprofit Roots

Our Founding Executive Director, Rose Chan Loui, spoke with Garrison Lovely on the legal and ethical stakes of nonprofit conversions, especially when billion-dollar tech players are involved.

News + Media
April 17, 2025
Trump threatens Harvard’s tax-exempt status: What to know

In a recent Hill article on Trump’s threat to Harvard’s nonprofit status, UCLA Law's Ellen Aprill warns that such political interference may be not only unprecedented—but illegal

News + Media
April 17, 2025
Profit or Purpose? OpenAI's $300 Billion Question, with Rose Chan Loui

Rose Chan Loui joins Capitalisn’t to discuss legal and ethical questions about OpenAI’s move from nonprofit to for-profit. From mission to Musk’s bid, this episode covers how AI’s future tests the limits of philanthropy and corporate control.

News + Media
April 16, 2024
Trump Administration Asks IRS to Start Process to Revoke Harvard’s Tax-Exempt Status

Senior Scholar in Residence Ellen Aprill comments in The Wall Street Journal on the Trump administration’s unprecedented push to revoke Harvard’s tax-exempt status, warning the move could carry criminal penalties.

News + Media
Faced With Anti-DEI Complaint, Gates Foundation Opens Scholarship to White Students

Chronicle of Philanthropy's latest report on the Gates Foundation’s choice to open its scholarships to students of all races takes important insights from Ellen Aprill on tax law and public policy.

News + Media
April 10, 2025
California is nudged into the ring between Musk and Altman

In “California is nudged into the ring between Musk and Altman,” LMPN's Rose Chan Loui offers critical legal insight into California Attorney General Rob Bonta’s potential role in the escalating battle over OpenAI’s nonprofit assets.

News + Media
Friday, April 4, 2025
‘Strategic Ambiguity’ of Trump DEI Orders Raises Big Questions About What’s Legal

As attacks on DEI ramp up, some question whether supporting race-conscious grantmaking could jeopardize a nonprofit’s tax-exempt status. Ellen Aprill reminds us that not every administration’s position qualifies as “fundamental public policy.”

News + Media
March 24, 2025
Hollywood’s DEI-Promoting Nonprofits Face Trump Assault: “The Higher Profile You Are, the Bigger the Target”

In light of recent attacks on DEI-promoting nonprofits, Ellen Aprill notes that even the threat of government scrutiny can be damaging, forcing organizations to divert resources toward legal battles instead of their mission.

News + Media
March 21, 2025
“A Very Complicated Entity”: Lesson from the DOGE-United States Institute of Peace Showdown

Ellen P. Aprill analyzes the legal and structural complexities behind the recent DOGE-United States Institute of Peace (USIP) conflict, highlighting the broader challenges posed by hybrid governmental-charitable entities.

News + Media
March 7, 2025
Emergency pod: Judge plants a legal time bomb under OpenAI (with Rose Chan Loui)

Rose Chan Loui joins Rob Wilbin of 80,000 Hours to discuss the major legal threats facing OpenAI's shift from nonprofit to for-profit control. They explore the court's signals, the board's fiduciary risks, and the implications for Open AI's future.

News + Media
February 24, 2025
Tech Trends- Can OpenAI Shed Nonprofit Status# 2-24

In this efficient radio spot,  Rose Chan Loui and interviewer Mike Dobuski sum up the OpenAI issues in one minute.

News + Media
February 24, 2025
OpenAI is trying to make itself Elon Musk proof

Founding Executive Director, Rose Chan Loui, was recently quoted in Yahoo Finance regarding Open AI's governance strategies, utilizing her expertise in nonprofit law to underscore the importance of protecting the organization's mission.

News + Media
Elon Musk’s OpenAI bid creates a legal maze and investor uncertainty—which is probably just what he wants

LMPN faculty discuss how Musk's action to bid on the company complicated OpenAI's transition to a completely for-profit business, which is probably exactly what he planned, even if he never anticipated his bid to be successful.

News + Media
February 13, 2025
OpenAI Conversion Sheds Nonprofit Purpose Without Justification

LMPN founding directors, Rose Chan Loui and Jill Horwitz, discuss legal concerns regarding OpenAI's ability to renounce its nonprofit mission without justification while restructuring.

News + Media
February 12, 2025
Emergency pod: Elon tries to crash OpenAI’s party (with Rose Chan Loui)

Founding executive director, Rose Chan Loui, offered her thoughts on how Musk's offer to Open AI raises legal and governance issues that could change the course of AI in the future, making it more than just a financial decision.

News + Media
February 11, 2025
Musk’s $97.4 Billion OpenAI Bid Piles Pressure on Sam Altman

Discussing Elon Musk's $97.4 billion bid for Open AI's nonprofit shareholding, Horwitz explained that "the question of the appropriate price is secondary to the question of whether the board should sell the charitable assets at all."

News + Media
February 11, 2025
Elon Musk’s $97bn offer is a headache for Sam Altman’s OpenAI

In recent article by The Economist, Jill Horwitz explains the fiduciary duty of Open AI's board to align with it's mission to ensure AI benefits all humanity, giving them the discretion to reject Elon Musk's unsolicited $97 billion bid.

News + Media
February 11, 2025
Sam Altman tells OpenAI staff that board hasn’t seen ‘anything official’ from Musk

Ellen Aprill recently contributed to a CNBC article about the process of OpenAI's board potentially receiving a formal bid from Elon Musk, and how they would have a legal obligation to review it.

News + Media
February 11, 2025
How Elon Musk $97.4 billion bid complicates matters for OpenAI

In an article by AP News, Rose Chan Loui and Jill Horwitz discuss the legal complications and governance hurdles of Elon Musk's bid for Open AI and how it would impact the nonprofit mission as they attempt to transition into a for-profit model.

News + Media
February 10, 2025
Elon Musk Leads $97.4 Billion Bid to Control OpenAI

Ellen Aprill discusses how Open AI's nonprofit board has a fiduciary duty to sell its assets at fair market value. Musk’s $97.4 offer sets that value incredibly high, creating “an enormous complication” for OpenAI’s plan to sever its nonprofit ties.

News + Media
February 4, 2025
Musk's lawsuit against OpenAI may go to trial in part, judge says

In recent Reuters article, Rose Chan Loui highlights how rare nonprofit to for-profit transitions are outside of the healthcare sector, raising important questions about the ethics and governance of AI.

News + Media
January 30, 2025
How Kash Patel’s Charity Aided Trump, and Patel Himself

Ellen Aprill recently provided insight to Kash Patel's use of his charity to further his and Trump's own agenda by spending more on self-promotion than charitable giving.

News + Media
January 17, 2025
Oakland judge postponed Musk suit against OpenAI even as interest in the case gathers

LMPN's founding executive director, Rose Chan Loui, contributed her knowledge on nonprofit corporation governance to this piece about the ongoing legal conflicts between Elon Musk and Sam Altman surrounding Open AI's hope to transition to for-profit.

News + Media
January 15, 2025
Unpacking the Most Important Paragraph in Loper Bright, by Ellen P. Aprill

In this article, Ellen P. Aprill examines Loper Bright Enterprises v. Raimondo overturning Chevron v. NRDC, and argues that the Supreme Court's guidance on congressional delegation to administrative agencies is inconsistent and lacks clarity.

News + Media
January 13, 2025
Ellen Aprill And Beverly Moran Receive AALS Tax Section Lifetime Achievement Award

LMPN's senior scholar in residence, Ellen Aprill, was recently awarded with the Section of Taxation’s Lifetime Achievement Award to honor her distinguished teaching career, service, and scholarship in the tax sector.

News + Media
January 6, 2025
Elon Musk vs. OpenAI: What to expect from the showdown in 2025

LMPN's founding executive director, Rose Chan Loui, discusses Open AI's priceless control position as a nonprofit as they are set to collide with xAI's Elon Musk this year.

News + Media
December 17, 2024
How OpenAI Hopes to Sever Its Nonprofit Roots

Senior Scholar in Residence at the Lowell Milken Center for Philanthropy and Nonprofits, Ellen Aprill, was recently quoted on the Sam Altman’s dual role as CEO of OpenAI’s for-profit company and board member of its nonprofit.

News + Media
Rose Chan Loui on OpenAI’s gambit to ditch its nonprofit

Rose Chan Loui, founding executive director of the Lowell Milken Center for Philanthropy and Nonprofits, discusses OpenAI’s innovative nonprofit structure and its complex balance between mission, investment, and control.

News + Media
11/20/2024
Legal complications await if OpenAI tries to shake off control by the nonprofit that owns the rapidly growing tech company

In their recent article for The Conversation, LMPN's Jill Horwitz, Rose Chan Loui, and Ellen Aprill analyze the legal and financial complexities of Open AI's proposed shift to for-profit.

News + Media
November 8, 2024
Ellen Aprill receives the Joanne M. Garvey Award for lifetime achievement and outstanding contribution in the field of tax law

Senior scholar in residence, Ellen Aprill, has been honored with the Joanne M. Garvey Award by the Taxation Section of the California Lawyers Association.

News + Media
October 28, 2024
Inside OpenAI’s multibillion-dollar gambit to become a for-profit company

Founding executive director, Rose Chan Loui, and founding faculty director, Jill Horwitz, provided their expertise on OpenAI’s nonprofit-to-for-profit restructuring and the potential challenges in preserving charitable assets in a recent Vox article.

News + Media
October 21, 2024
Is OpenAI being fair to its non-profit?

Rose Chan Loui and Jill Horwitz, recently spoke to Transformer News about OpenAI’s unique legal structure and the balance between nonprofit control and for-profit interests.

News + Media
Friday, October 18, 2024
JD Vance Campaign Event With Christian Right Leaders May Have Violated Tax and Election Laws, Experts Say

Republican vice-presidential nominee JD Vance’s appearance at a far-right Christian revival tour last month may have crossed the line into campaign intervention by charitable groups.

News + Media
Monday, October 14, 2024
Changing OpenAI’s nonprofit structure could have big consequences

Artificial intelligence company, Open AI, could soon face significant challenges regarding its nonprofit roots, even as its valuation skyrockets to $157 billion.

News + Media
10/7/2024
The big winner if OpenAI becomes a for-profit business? Microsoft.

OpenAI is exploring a shift from its nonprofit origins to a for-profit model, a move that could greatly benefit Microsoft (MSFT), its major backer. If approved, the transition would allow OpenAI to operate more like a startup, opening new opportunities for growth and investment.

News + Media
Monday, October 7, 2024
OpenAI looks to convert from nonprofit roots and become for-profit company

OpenAI’s history as a nonprofit research institute that also sells commercial products like ChatGPT may be coming to an end as the San Francisco company looks to more fully convert itself into a for-profit corporation accountable to shareholders.

News + Media
October 4, 2024
Jill Horwitz quoted in Business Insider article regarding Open AI's $6.6 billion funding deal

OpenAI's historically large $6.6 billion funding round is bringing in checks from some of the biggest technology and venture capital investors.

News + Media
September 30, 2024
OpenAI’s Complex Path to Becoming a For-Profit Company

Converting from a nonprofit happens rarely, especially for organizations this wealthy. OpenAI has two years to do so.

News + Media
August 20, 2024
Open AI's structure raises questions about protecting its charitable mission

In the latest development in the OpenAI saga, Elon Musk has, for the second time sued the group of entities known as OpenAI this time in the federal court in Northern California.

News + Media
June 11, 2024
Rose Chan Loui quoted in Forbes article regarding the Fearless Fund litigation

The United States Court of Appeals for the 11th Circuit last week delivered a blow to philanthropic efforts to advance racial equity.

News + Media
May 13, 2024
NBC4: Here’s What Nonprofit Expert Says About Harry and Meghan’s Charity

NBC Universal’s Karma Dickerson interviewed Executive Director Rose Chan Loui about Archewell Foundation.

News + Media
April 29, 2024
Mayor Bass visits UCLA Law to discuss philanthropic responses to homelessness

People from across the UCLA School of Law community welcomed Los Angeles mayor Karen Bass to the law school on April 12 for a high-level forum on the key role that philanthropic enterprises can play in solving the homelessness crisis.

News + Media
April 20, 2024
LMPN Announcement: Executive Director Chan Loui Receives Governors’ Award from Stanford

LMPN Executive Director Chan Loui, a Stanford University alumna, was awarded the Governors’ Award at a ceremony in April 2024.

News + Media
March 5, 2024
NEO Law Blog: WCTEO 2024 Highlights

Gene Takagi of NEO Law Group sums up highlights from the 27th Western Conference on Tax-Exempt Organizations in the firm’s March 25, 2024, Nonprofit Law Blog.

News + Media
March 4, 2024
CNBC Squawkbox: Elon Musk could face an uphill battle regarding his standing in the case: UCLA Law’s Rose Chan Loui

LMPN Rose Chan Loui joins ‘Squawk Box’ to discuss Elon Musk’s lawsuit against OpenAI and CEO Sam Altman, whether Musk has a legitimate argument in the case, OpenAI’s for-profit interests, and more.  

News + Media
February 29, 2024
Tradeoffs: How Pushing Hospitals to Give Away Free Healthcare Could Backfire

In this podcast by Tradeoffs, LMPN Faculty Director Jill Horwitz talks about the difference between for-profit and nonprofit hospitals.

News + Media
February 15, 2024
UCLA Law: UCLA Law launches center to address ‘revolutionary change’ in philanthropy and nonprofits

The law school established the Program on Philanthropy and Nonprofits in 2021, which has now transformed into the Lowell Milken Center for Philanthropy and Nonprofits.

News + Media
January 11, 2024
UCLA Law launches center to address ‘revolutionary change’ in philanthropy and nonprofits

Los Angeles, CA – UCLA proudly announces the launch of the Lowell Milken Center for Philanthropy and Nonprofits (LMPN).

News + Media
January 8, 2024
Tax Notes: Board Control of a Charity’s Subsidiaries: The Saga of OpenAI

LMPN Senior Scholar in Residence Ellen Aprill, Faculty Director Jill Horwitz, and Executive Director Chan Loui write about the nonprofit structure and governance of OpenAI.  

News + Media
December 20, 2023
The Conversation: What do universities owe their big donors? Less than you might think, explain 2 nonprofit law experts

Jill Horwitz and Ellen Aprill address the nonprofit law implications of donor complaints about university responses to debates and demonstrations triggered by Hamas’ terrorist attacks on Israel and the Israeli government’s military campaign in Gaza.  

News + Media
December 18, 2023
LAist: Nonprofit Led By OC Supervisor's Daughter Failed To Submit Required Audits For Millions In Spending, Records Show

LMPN Executive Director Rose Chan Loui comments on the compliance failures of an Orange County nonprofit that was given millions of dollars of County funding.  

News + Media
October 11, 2023
UCLA Law: ‘Heroic’ journey: How Jill Horwitz brought the ‘Restatement of Charitable Nonprofits’ to life

Learn about UCLA Law professor Jill Horwitz’s work as the reporter for the Restatement of the Law

News + Media
June 5, 2023
Jill Horwitz receives ABA’s Outstanding Nonprofit Lawyer Award

News + Media
March 14, 2023
LMPN Announcement: Rose Chan Loui Appointed to the Mayor’s Fund for Los Angeles

Rose Chan Loui is the inaugural Director of the Program on Philanthropy and Nonprofits at UCLA School of Law.

News + Media
September 21, 2021
UCLA Law: UCLA Law Launches Program on Philanthropy and Nonprofits

With the philanthropy world on the precipice of revolutionary change due to the pending baby boomer wealth transfer, UCLA School of Law today announced the formation of the Program on Philanthropy and Nonprofits.

Lowell Milken Center
Lowell Milken Center
LOWELL MILKEN CENTER ON PHILANTHROPY AND NONPROFITS
LOWELL MILKEN CENTER ON PHILANTHROPY AND NONPROFITS
LOWELL MILKEN CENTER ON PHILANTHROPY AND NONPROFITS
Educational

Explore our comprehensive educational programming designed to enrich the knowledge and skills of law students, nonprofit professionals, board members, and philanthropists.

For Law Students
For Nonprofit
Professionals
For Boards
For Philanthropists
Thought
Leadership

In the dynamic world of philanthropy and nonprofits, the Lowell Milken Center fosters an environment of intellectual growth and collaboration. Our Thought Leadership initiatives provide a platform for scholars, nonprofit leaders, and the broader community to engage in meaningful dialogue, share insights, and shape the future of the sector.

Conferences

We host conferences targeted at the interests and needs of our various constituencies. Our academic conferences invite scholars, nonprofit and foundation leaders, practitioners and regulators to delve into the intricacies of the philanthropic and nonprofit sector.

External Speaking Engagements

Our faculty and staff are frequently invited to share their expertise and insights at national and international nonprofit law sector and academic conferences.

Scholarship

Our extensive range of research and publications focuses on critical nonprofit law issues. Contributing to scholarly discourse, guiding practitioners, and informing policy debates, our work aims to enhance understanding and effectiveness within the sector.