With experience in a broad range of tax issues, Mackenzie is able to provide comprehensive advice to both tax-exempt organizations and taxable companies. She has particular expertise with advising tax-exempt organizations with taxable subsidiaries, organizations with unrelated business income-generating activities, and organizations requesting rulings from the IRS. In addition, Mackenzie has extensive experience working with U.S.-based and foreign-based healthcare organizations, higher education organizations, non-government organizations, faith-based organizations, and private foundations.
Prior to joining Dorsey, Mackenzie was a Senior Manager at Ernst & Young and a Senior Tax Law Specialist with the IRS. While at the IRS, Mackenzie coordinated with other IRS technicians, Chief Counsel, and Treasury personnel in the Tax Exempt and Government Entities (TE/GE) and Large Business and International (LB&I) divisions to draft taxpayer guidance and create IRS systems and procedures to implement significant new tax legislation including the Patient Protection and Affordable Care Act (ACA) and the Foreign Account Tax Compliance Act (FATCA). Her clients benefit from her experience and connections at the IRS, which she uses in her legal advice and in trainings she provides to clients.
Mackenzie is a Senior Attorney in Dorsey’s Health Transactions & Regulations Group and Non-Profit & Tax Exempt Organizations Group.
- Advises clients on federal and state tax matters for U.S. and foreign tax-exempt organizations, including issues surrounding tax-exempt status, formation and choice of entity, and state and local charity regulation requirements.
- Conducts comprehensive unrelated business income analysis for U.S. and foreign-based tax-exempt health care systems, higher education organizations, public charities, and private foundations.
- Advises on structuring and drafting conversion of taxable entities to tax-exempt organizations.
- Represents taxpayers under audit with the IRS and state tax authorities.
- Collaborates with audit teams to conduct tax provision reviews for external audit and financial statement preparation.
- Supervises and reviews preparation of tax filings for taxable and tax-exempt clients, including IRS Forms 1041, 990, 990-PF, 1120 and corresponding state requirements.
News & Resources
- Minnesota CLE Nonprofit Law Conference: Closing the Doors – A Dissolution Primer for Nonprofits (March 9, 2021)
- IRS TE/GE Exempt Organizations Council Exempt Organizations Update: Healthcare and Hospital Issues (March 4, 2021, co-presenter with Preston Quesenberry at KPMG and Brian Deppe at Intermountain Healthcare)
- Minnesota Council on Foundations: How to Make a Successful Program Related Investment (PRI) (September 30, 2020, co-presenter with Jeff Ochs at Venn Foundation, Larry Mohr at Baker Tilly, and Karen Gries at CLA)
- Minnesota CLE Nonprofit Law Conference: Preparation, Execution and response – Planning for an Audit and What to Do When the Audit Goes Badly (March 3, 2020, co-presenter with Karen Gries at CLA)
Industries & Practices
- Non-Profit & Tax Exempt Organizations