Mackenzie P. McNaughton

Of Counsel

Minneapolis + 1.612.217.8885

Mackenzie McNaughton served with the Internal Revenue Service (IRS) for nearly a decade and has a wealth of knowledge with IRS rules and policies, especially those affecting exempt organizations. During her recent role as senior technical advisor (exempt organizations) with the IRS, Mackenzie advised the IRS director of exempt organizations and government entities (EO/GE) on day-to-day technical issues impacting exempt organizations and liaised with colleagues in Chief Counsel, Division Counsel, and Treasury to collaborate on issues relating to exempt organizations.

Mackenzie's IRS experience and background advising clients while at prior law and accounting firms gives her unique insight into the challenges and opportunities for exempt organizations in a complex regulatory and compliance environment. During her first role at the IRS, Mackenzie assisted with the implementation of the Affordable Care Act (ACA) legislation and navigated its impact on tax-exempt hospital and health care systems, accountable care organizations (ACOs), senior living facilities, and other health care entities and insurers.

Mackenzie also has experience advising on state nonprofit corporate governance issues, and federal and state tax matters for U.S. and foreign tax-exempt organizations, including issues surrounding tax-exempt status, unrelated business income-generating activities, items related to private foundation or public charity classification status, political activities, and private foundation excise tax assessments and requests for abatement. Her corporate governance practice includes board fiduciary trainings and the development and implementation of internal policies, including document retention, whistleblower, conflict of interest, and other policies that help clients navigate complex regulatory compliance requirements and mitigate legal and operational risks.

  • March 12, 2026
    Hennepin County Bar Association, Lawyers Impacting the Nonprofit Community
  • March 5, 2026
    TEGE Exempt Organizations Council, Exempt Organizations Update