Rose Chan Loui is the Founding Executive Director of the Lowell Milken Center on Philanthropy and Nonprofits. As Executive Director, Chan Loui is the senior member of the Center’s team and is responsible for developing and managing the Center’s programming. The Center for Philanthropy and Nonprofits was established in October 2023 and aims to expand the law school’s nonprofit law curriculum, provide educational resources to nonprofit staff and practitioners, and provide scholarship and thought leadership for academics, nonprofit leaders, practitioners, regulators, and philanthropists.
Prior to joining UCLA Law, Chan Loui was Of Counsel at Rodriguez Horii Choi & Cafferata, LLP, one of the nation’s pre-eminent firms in the area of nonprofit law. At RHCC, Chan Loui worked with nonprofit organizations at all stages of the nonprofit life cycle, from incorporating and obtaining their tax-exempt status, to setting up and implementing their governance structure, and through all facets of operations. She has a particular expertise in structuring and implementing advocacy and lobbying programs. Chan Loui also focused on representing nonprofits, businesses and individuals in federal and state tax controversy matters. Chan Loui started her legal career at Latham & Watkins in Los Angeles, where she worked on litigation and tax matters and served on the Associates Committee. She continued her career at ARCO, where she was a member of the tax controversy group and worked on matters from the examination stage through Appeals and Tax Court, Claims Court and District Court. Chan Loui subsequently co-founded the tax controversy group at Deloitte.
Chan Loui has been active in numerous local nonprofits throughout her career and brings that hands-on experience to her job as Director of the Center. She currently serves as board chair of East West Players, as vice-chair of the Mayor’s Fund for Los Angeles, and as the incoming board chair of the Chronicle of Philanthropy. A dedicated alumna of Stanford University, Chan Loui is a longtime board member, and was co-president, of the Stanford Club of Pasadena. She is a member of Stanford Associates, an honorary society for the university’s top volunteers, and has been awarded by the society with the Governors’ Award and an Award of Merit.
Chan Loui attended Stanford as an international student. She graduated with distinction and double-majored in communications and international relations. Chan Loui received her J.D. from New York University School of Law, where she was an editor of the Law Review. She is a member of the California Bar and was recently elected to the membership of the prestigious American Law Institute.
EDUCATION
New York University School of Law, J.D. 1986
- Note and Comment Editor, New York University Law Review
Stanford University, B.A., with distinction, 1982.
- Majors in Communications (Journalism) and International Relations
- Minor in English
UCLA LAW POSITIONS
Lowell Milken Center for Philanthropy and Nonprofits
- Founding Executive Director. October 2023-Present
Program on Philanthropy and Nonprofits, Lowell Milken Institute on Business Law and Policy
- Director, October 2022-October 2023.
As the senior staff member of the Center (formerly the Program), Chan Loui is responsible for designing and implementing all programs and operations. The mission of the Center is to deepen the understanding of the philanthropic and nonprofit sector and to promote solutions to its problems through education, thought leadership, and scholarship.
PREVIOUS LAW-RELATED EMPLOYMENT
Rodriguez Horii Choi & Cafferata, LLC, Los Angeles, California
Nonprofit Law Representative Matters:
- Representation of clients in formation and application for tax-exemption of nonprofit entities that included nonprofit newspapers, a historical building organization, arts organizations, economic equity and racial justice organizations, and religious organizations.
- Consulting regarding structure and operations of various types of nonprofit entities, including private foundations making grants to foreign charities, 501(c)(4)s affiliated with 501(c)(3)s, and 501(c)(6) membership organizations.
- Review of nonprofit clients’ advocacy work and communications. Significant projects include structuring the advocacy and educational communication campaigns relating to ballot measures and advising clients regarding the funding of such campaigns.
- Projects for several private foundations to revise their grant agreement templates in order to achieve a better balance between accomplishing grantor purpose and allowing grantee flexibility.
- Advice and compliance support relating to nonprofit activities encompassed by the Foreign Agents Registration Act.
- As part of a complex transaction, structured the contribution of a limited liability corporation by a for-profit entity to a public charity through the use of a new supporting organization.
- Conducted workshops and seminars for public charity and private foundation boards of directors, board advocacy committees, government affairs departments, and grant personnel regarding legislative lobbying and political campaign laws.
Tax Controversy Representative Matters:
- Advised corporate client in guiding multiple employees being separately audited by the IRS on the ground that the employees’ charitable contributions of company stock constituted assignment of income.
- Defended individual taxpayers in significant audit related to tax consequences of sales of stock and succeeded in persuading the FTB that complete withdrawal of the issue was the correct result.
- Defended individual taxpayer in FTB audit regarding trader status and application of the mark-tomarket rules, which resulted in the FTB dropping the audit.
- Represented individual taxpayers in FTB audit relating to residency and income sourcing issues, resulting in a significantly reduced assessment.
Deloitte & Touche. Los Angeles, California
- Senior Tax Manager, Co-founder, Pacific Southwest Tax Controversy Group, 2003-2005.
- Advised large and mid-sized clients on all aspects of IRS Examination and Appeals.
Atlantic Richfield Company. Los Angeles, California
- Senior Tax Attorney, Federal Income Tax Controversy Group, 1992-2003.
- Represented the company through IRS examination phase, at IRS Appeals, in Tax Court, and in district court on a wide range of federal tax issues.
Latham & Watkins, Los Angeles, California
- Associate, 1986-1991. Tax Department, 1987-1991. Associates Committee, 1987-1989.
- Tax experience encompassed transactional advice, drafting of ruling requests, federal and state tax controversy work, and advice to tax-exempt organizations. As a second- and third-year associate, served on the Associates Committee, which evaluated associates, assigned work to youngest associates, and determined year-end bonuses.
Paul Weiss Rifkind and Wharton, New York, New York
PUBLICATIONS
- Chan Loui, ‘Can OpenAI Abandon Its Non-Profit “Purpose”?’ Promarket, George J. Stigler Center for the Study of the Economy and the State at the University of Chicago Booth School of Business (April 23, 2025).
- Chan Loui and Horwitz, Op-Ed, "OpenAI Conversion Sheds Nonprofit Purpose Without Justification,” Bloomberg Law (February 13, 2025).
- Aprill, Horwitz, Chan Loui, “Legal complications await if OpenAI tries to shake off control by the nonprofit that owns the rapidly growing tech company,” The Conversation (November 20, 2024).
- Chan Loui, "Open AI's structure raises questions about protecting its charitable mission", Los Angeles Daily Journal (August 20, 2024).
- Chan Loui, “The Foreign Agents Registration Act: Noncompliance Could be Costly,” Taxation of Exempts (July/August 2024).
- Aprill, Chan Loui, Horwitz, “The Untold Nonprofit Story of OpenAI”, The Columbia Law School Blue Sky Blog (March 2024).
- Aprill, Chan Loui, Horwitz, “Board Control of a Charity’s Subsidiaries: The Saga of OpenAI” - Viewpoint, Tax Notes Federal (Volume 182, January 8, 2024).
- “The Foreign Agents Registration Act and Tax Exempts: It May Apply to You” — Taxation of Exempts (May/June 2020).
- “California Fights to Unmask Donors” — Special Report, The Exempt Organization Tax Review (Volume 71, Number 2, February 2013).
- Update Co-Author, Continuing Education of the Bar, Advising California Nonprofit Corporations, Chapter 22, “Suspension, Forfeiture, and Revocation of Tax-Exempt Status.”
RECENT AND UPCOMING PRESENTATIONS
- Co-Speaker with Ellen Aprill, Presentation for the Goldhirst Foundation, “Strengthening Nonprofit Governance” (November 2025).
- Conference Chair, “2ⁿᵈ Annual Conference: Crafting a Thriving Nonprofit Arts Sector,” Lowell Milken Center for Philanthropy and Nonprofits, UCLA Law (May 2025).
- Conference Chair, “Nonprofits and Artificial Intelligence,” Lowell Milken Center for Philanthropy and Nonprofits, UCLA Law (April 2025).
- Speaker, “Foundation Basics,” The Aspen Institute Artist Endowed Foundations Initiative, 2025 Seminar on Strategy (March 2025).
- Planning Committee; Panelist, “The Challenges of For-Profit/Nonprofit Structures”, 28ᵗʰ Western Conference on Tax-Exempt Organizations (February 2025).
- Organizer, “Sowing the Seeds of Generosity: Maximizing the Benefits of Philanthropic Giving,” Lowell Milken Center for Philanthropy and Nonprofits and Lowell Milken Institute for Business Law and Policy, UCLA Law (November 2024).
- Developed and taught workshop, “Effective Nonprofit Board Leadership,” UCLA Law (Fall 2024).
- Organizer/Panelist, “OpenAI: Nonprofit in Name Only,” Business Law Breakfast, Lowell Milken Center for Philanthropy and Nonprofits and Lowell Milken Institute for Business Law and Policy, UCLA Law (October 2024).
- Moderator, Career Panel Series: Careers as University Counsel (October 2024).
- Moderator, Panel discussion on “Legacy of Nonprofits and Philanthropy,” Arts for LA State of the Arts Summit (October 2024).
- Organizer/Moderator, “Nonpartisan Advocacy: How 501(c)(3)s Can Educate and Advocate During Election Season” (October 2024).
- Moderator, “Career Panel Series: Nonprofit Practice at Law Firms” (September 2024).
- Speaker, “OpenAI Structure and Governance,” American Bar Association Real Property Trust and Estate Law Section (July 2024).
- Moderator, “Nonprofit Leadership Panel,” The Modern C-Suite Conference: Navigating AI and Technology, UCLA Law Executive Education Program (June 2024).
- Organizer, “Philanthropy, Business, Government and the Homelessness Crisis,” featuring Los Angeles Mayor Karen Bass (May 2024).
- Moderator, “Bruin Bite: The Role of General Counsel in a Nonprofit Organization,” UCLA Law Executive Education Program (April 2024).
- Organizer, “1ˢᵗ Annual Conference: Crafting a Thriving Nonprofit Arts Sector,” An Arts Convening featuring National Endowment of the Arts Chair Dr. Maria Rosario Jackson in conversation with Richard Tate, CEO, California Wellness Foundation, and Kristin Sakoda, Director of the Los Angeles County Department of Arts and Culture, Lowell Milken Center for Philanthropy and Nonprofits, UCLA Law (February 2024).
- Presenter, Workshop on Advocacy, “Crafting a Thriving Nonprofit Arts Sector,” Lowell Milken Center for Philanthropy and Nonprofits, UCLA Law (February 2024).
- Planning Committee Co-Chair; Panelist, “International Hot Topics”; Planner, “Can Nonprofits Save Journalism?” 27ᵗʰ Western Conference on Tax-Exempt Organizations (January 2024).
- Organizer/Moderator, “The Business of Giving: Considerations for Donors and Charities When Giving and Accepting Business Interests” with Speaker David Shevlin, Head of Nonprofit Law Practice, Simpson Thacher & Bartlett, Lowell Milken Institute on Business Law and Policy 10-Year Anniversary (October 2023)
- Guest Lecturer, Nonprofit Law and Policy Class, UCLA Law (Fall 2023).
- Moderator, Career Panel: “Lawyers in Nonprofit Arts,” UCLA Law Program on Philanthropy and Nonprofits (October 2023).
- Moderator, Career Panel: “Lawyers at Foundations,” UCLA Law Program on Philanthropy and Nonprofits (September 2023).
- Organizer/Panelist, “The ‘Gift’ of a Business,” Western Region Planned Giving Conference (May 2023).
- Guest Lecturer, “Basics of a 501(c)(3),” Colburn Conservatory School of Music, Graduate Student course on “Music and Philanthropy” (2023).
- Organizer/Moderator, Panel on “Nonprofit Boards,” Lowell Milken Institute on Business Law and Policy (2023).
- Panelist, “Fiduciary Duties,” 26ᵗʰ Western Conference on Tax-Exempt Organizations (December 2022).
IN THE MEDIA
- E. Schilling, Bloomberg Law, “Open-Source Software Groups Face Tricky Road to Tax-Exemption” (July 29, 2025).
- R. Drew, The Information, “OpenAI’s New Path to Conversion Faces Activist Opposition” (May 29, 2025).
- S. Hashim and L. Bye, Transformer Weekly, “Who Will ‘Control’ OpenAI?” (May 9, 2025).
- Nikkei Digital Governance, “”Altman’s ‘Profit Prioritization’ Raises Alarm Amon AI Safety Advocates” (May 9, 2025).
- R. Price, Business Insider, “OpenAI thinks it has defused its multi-billion dollar time bomb” (May 6, 2025).
- M. Zeff, TechCrunch, “What OpenAI’s restructuring plan means for its corporate future” (May 6, 2025).
- M. O’Brien and T. Beaty, “OpenAI reverses course and says its nonprofit will continue to control its business” (May 5, 2025).
- A. Keenan, “Nonprofit keeps control over OpenAI as ChatGPT creator sheds for-profit conversion plans” (May 5, 2025).
- Bloomberg, “OpenAI Walks Back For-Profit Plan, Nonprofit to Keep Control” (May 5, 2025).
- G. Lovely, Obsolete, “Inside OpenAI’s Controversial Plan to Abandon its Nonprofit Roots (April 17, 2025).
- C. Difeliciantonio, T. Katzenberger, C. Mui, Politico, “California is nudged into the ring between Musk and Altman” (April 10, 2025).
COMMUNITY LEADERSHIP
Current Activities:
East West Players. Los Angeles, California.
- Board Chair, 2021-Present; Executive Committee Member, ca. 2018-Present; Director, 2017-Present
Mayor’s Fund for Los Angeles. Los Angeles, California.
- Vice Chair; Finance and Audit Committee; Nominations & Governance Committee. 2023-Present.
Chronicle of Philanthropy. Washington, District of Columbia.
- Board Chair; Finance and Audit Committee. 2023-Present.
Stanford Club of Pasadena. Pasadena, California.
- Board Member. ca. 2016-Present. Board Co-Chair. 2019-2022.
Stanford Class of 1982:
- Class Correspondent. 2020-Present. 40ᵗʰ Reunion Co-Chair. 2021-2022. 20ᵗʰ through 40ᵗʰ Reunions, Major Gifts Committee, Reunion Planning Committee
Additional Stanford University Activities:
- Admitted Students Reception Panel, Parent Speaker (2019). Admissions Alumni Interviewer, 2017-Present.
- Stanford Professional Women, Member (to Present) and Former Board Member (late 1980s). Stanford
- Asian Pacific American Alumni Club, Member.
Previous Activities:
New York University School of Law
- Class of 1986 35th Reunion Committee.
Episcopal Communities and Services
Weingart Center
- Gala Committee, 2017-2019.
Twelve Oaks Foundation
- President. 2019-2021. Board Member, 2015-2022.
National Charity League-Glendale Chapter
Twelve Oaks Defense Committee, 2013-2015.
- President. 2013-2014. VP-Philanthropy, 2012-2013. Parliamentarian, 2011-2012. Member, 2010-2016. Sustaining Member, 2016-Present.
Lineage Dance Company
Flintridge Preparatory School
- Trustee. 2008-2014. Chair of Trustee Committee, ca. 2012-2014.
Flintridge Preparatory School Parent Association
- Positions included President; VP-Gala; Secretary; Class Parent. 2002-2014 Community Scholarship Foundation of Loa Canada VP-Scholarships.
Palm Crest Elementary School Parent-Teacher Association
- Officer positions included President and Secretary.
- Volunteer positions included Art Docent and Student Newspaper Advisor.
Palm Crest Elementary School Site Council
La Canada Flintridge Educational Foundation
- Positions included President and VP-Benefit, 1995-2002.
Southern California Chinese Lawyers Association
- Board Member. ca. late 1980s to mid-1990s.
SERVICE AWARDS
Stanford University Alumni Association.
- Governor’s Award (2024). Award of Merit (2023).
- Stanford Associates (honorary association).
La Canada Flintridge Educational Foundation.
- Spirit of Outstanding Service Award (2011).
La Canada Unified School District Parent Teacher Association.
