Kendi is a trusted advisor to tax-exempt organizations, including colleges, universities, health care organizations, cultural institutions, and corporate and family foundations. She is a leader in the firm’s colleges and universities practice and heads the firm’s tax-exempt organizations practice. She has obtained tax-exempt status and IRS rulings for numerous clients and provides practical guidance on a wide range of issues these organizations encounter, from day-to-day questions about grant making, filing requirements, and charitable giving to highly sensitive matters involving conflicts of interest, corporate governance, executive compensation, and arrangements with for-profit parties. Kendi is often lead tax counsel in transactions that involve non-profit organizations, including affiliations, mergers, asset acquisitions, and dissolutions, notably advising on tax exemption issues. She is also active in pro bono matters and is dedicated to non-profit board service. Prior to attending law school, Kendi worked in fundraising for a major research university and earned a master’s degree in education, focused on higher education administration.


  • Serve as tax counsel for multiple tax-exempt health care systems in affiliation transactions, with both non-profit and for-profit parties
  • Form and secure tax-exempt status for new entities in affiliations and reorganizations of health care systems
  • Conducted in-depth analysis of restricted gift issues for tax-exempt cultural organization in connection with a significant asset transfer, including securing court and Attorney General approvals
  • Worked with state regulators and non-profit grant making organization’s board of directors and officers to achieve successful resolution of internal investigation involving director conflict of interest, including implementing policies and internal controls to identify and manage conflicts
  • Advise non-profit organizations on structuring vehicles to enable commercialization of research while maintaining compliance with tax exemption requirements
  • Counsel boards of directors and compensation committees on compensation matters unique to tax-exempt organizations, including IRS “intermediate sanctions” rules
  • Work with for-profit employers to establish tax-efficient vehicles for philanthropy and to determine how to provide rapid relief to employees suffering from disasters and other emergencies
  • Collaborate with charities and their donors to structure venture philanthropy and other innovative giving arrangements
  • Work with corporate and family foundations to further their grant making goals, including grants to non-U.S. organizations and non-charities
  • Assess tax exemption and unrelated business income tax consequences associated with non-profit organizations participating in joint ventures with for-profit parties, including through LLCs
  • Provide informed review of drafts of publicly-disclosed IRS and state tax and information filings for non-profit organizations, with special emphasis on the IRS Form 990

Areas of Practice