This session describes the nonprofit and for-profit legal entities comprising the business of OpenAI (the developer of ChatGPT), explains how that business structure was arrived at, and offers more generalized information about for-profit subs of nonprofits/charities, including:

- Motivations for establishing this type of relationship;

- Situations in which this type of relationship could be advantageous;

- Characteristics of the relationship, with a focus on what the entities can and cannot do under the IRS regulations governing nonprofits qualifying for the federal income tax exemption under 501(c)(3); and

- Responsibilities of the management of each entity and how they can conflict.

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