Jonathan Grissom helps nonprofit organizations tackle the full range of legal, tax and operational complexity that comes with impact-driven work. He works closely with clients across the nonprofit sector — including public charities, private foundations, research institutes, hospitals, advocacy groups, religious and educational institutions, business leagues, trade associations, philanthropic organizations and more — bringing steady and thoughtful guidance at each stage of the nonprofit lifecycle.

Jonathan advises on:

  • Entity selection and formation
  • Federal and state tax-exempt applications, including IRS Forms 1023, 1024, 990 and 990PF
  • Nonprofit compliance, public support tests and charitable solicitation rules
  • Fiscal sponsorships, endowments, grantmaking and joint ventures
  • Program-related investments (PRIs) and tax-exempt bond financings
  • Lobbying, political activity and unrelated business income
  • Property and tax exemptions
  • Nonprofit mergers and dissolutions

He also represents organizations before the IRS, California Franchise Tax Board, State Board of Equalization and the California Attorney General’s Office.

Education

  • University of San Diego School of Law (LL.M., 2003)
    • Master of Laws in Taxation
  • University of San Diego School of Law (J.D., 1997)
    • San Diego Law Review, Lead Editor
  • California Polytechnic State University, San Luis Obispo (B.S., 1994)
    • Business Administration, Corporate Finance

Bar Admission

  • California

Court Admissions

  • California Supreme Court and all appellate and trial courts
  • U.S. District Court, Southern District of California
  • U.S. District Court, Southern District of California
  • U.S. District Court, Eastern District of California
  • U.S. District Court, Central District of California
  • U.S. Tax Court

Professional Affiliations

  • State Bar of California
  • American Bar Association
  • San Diego County Bar Association
  • California Lawyers Association
    • Taxation Section, Chair of the Tax Exempt Organizations Committee, 2021-2023

Recognition

  • Selected for inclusion in Best Lawyers in America® for:
    • Business Organizations, 2021-2026
    • Nonprofit/Charities Law, 2021-2026
    • Tax Law, 2021-2026
  • Named a “Leaders in Law” finalist by San Diego Business Journal, 2021
Publications
All Publications
Preparing Tax-Exempt Organizations for the New Covered Employee Rules for the Expanded Code §4960 Excise Tax
Key Takeaways: The OBBBA significantly expanded Code §4960 for taxable years beginning after Dec. 31, 2025, broadening the scope of employees that tax-exempt organizations must evaluate for potential excise tax exposure. The definition of “covered employee” for tax-exempt organizations now covers any employee of a tax-exempt organization who receives remuneration exceeding $1 million or an excess parachute payment during the applicable taxable year — extending Code §4960 beyond the prior focus on an organization's five highest-compensated employees. Tax-exempt organizations should review compensation arrangements, deferred compensation plans and compliance processes before the new rules take effect, particularly where compensation may approach or exceed the $1 million threshold. The One Big Beautiful Bill Act (OBBBA) amended Code §4960, which imposes an excise tax on certain excess
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Congress Considers Expanded Schedule H Reporting Requirements for Tax-Exempt Hospitals
Key Takeaways Congress is considering expanded Schedule H reporting requirements for certain tax-exempt hospital organizations required to file Form 990 to require more detail on community benefit, charity care, 340B activity and tax-exemption value. The proposal reflects growing scrutiny of whether tax-exempt hospitals provide sufficient community benefit to justify their favorable tax status. More granular public reporting could increase regulatory, congressional and watchdog attention on hospital spending, allocation methods and documentation. Tax-exempt hospitals should assess whether current systems can support the data Congress may expect in future Schedule H reporting. Key areas include charity care, CHNA-related spending, financial assistance applications, facility-level financial data and 340B program information. Tax-exempt hospitals and health systems have faced increasing scrutiny from Congress, state regulators and industry watchdogs on
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