Michael focuses his practice on representing nonprofit organizations in a broad range of corporate governance, tax, and transactional matters. He advises private foundations, public charities, university foundations, tax-exempt health systems, business associations, and other exempt organizations on complex legal and operational issues throughout their lifecycle.
Michael’s experience includes the formation and structuring of nonprofit entities; mergers, acquisitions and dispositions; joint ventures and strategic collaborations; internal reorganizations; and tax-efficient organizational structures. He also regularly counsels clients on private foundation compliance, including excess business holdings, self-dealing, jeopardizing investments, taxable expenditures, and other Chapter 42 excise tax matters. His practice also encompasses unrelated business income tax analysis, applications for federal tax-exempt status, and Section 501(r) compliance for tax-exempt hospitals under the Affordable Care Act.
Michael draws on his experience spanning law, finance, tax consulting, and in-house leadership to find pragmatic, business-focused solutions that account for clients’ legal, tax, financial, and operational objectives. Prior to practicing law, he served as executive director of tax at a large tax-exempt health system and worked in the exempt organizations tax practice of a Big Four accounting firm, advising Section 501(c)(3) organizations on tax, governance, compliance, and Affordable Care Act matters.
Michael is actively involved in the nonprofit community and serves as chair of the American Health Law Association’s Tax and Finance Practice Group.
- *Advised a national charity on the formation of a venture fund.
- *Utilized a novel supporting organization structure to create an energy-as-a-service arrangement for a tax-exempt hospital.
- *Advised a private foundation on its expansion from $35 million in assets to over $1.2 billion in assets.
- *Created a nonprofit entity for the preservation and protection of parks and wildlife.
- *Created a new parent entity as a Type II Supporting Organization to allow a national nonprofit to pursue member substitutions.
- Created a new Supporting Organization with a multi-tier membership structure to allow for activities to be provided to other organizations without incurring unrelated business structure.
- Advised a university foundation on structuring a Name, Image and Likeness (“NIL”) program.
- Advised a nonprofit health system on a joint venture with a private equity fund, including discrete foundation and grant considerations.
- Represented governmental entity on Private Letter Ruling regarding status as an integral part of the state.
- Analyzed and restated governance documents, governance structure and corporate policies to become compliant and institute best practices related to Florida’s new Nonprofit Corporations Act.
*The above matters were handled by Mr. Kuczynski prior to joining McGuireWoods LLP.
Events
- Presenter, "Protecting the Tax Exemption Privilege: Guidance on Taxes, Audits, and More for Nonprofit Hospitals," American Health Law Association, Webinar, January 30, 2026
- Presenter, "2025 Tax Issues for Health Care Organizations, Digesting the Acquisition," American Health Law Association, December 2025
- Presenter, "Tax law changes and tax-exempt organizations," TEGE Exempt Organizations Council, November 21, 2025
- Presenter, "2024 Virtual Fall Tax Meeting Standards of Tax Practice Session," American Bar Association, September 27, 2024
Insights
- Author, "Florida’s New Nonprofit Corporation Act: Key Governance and Transactional Considerations for Health Systems," American Health Law Association, July 16, 2026
- Author, "Dormant Entities and Weighing the Risk of Revocation—Private Letter Ruling 202437007 and Its Impact on Keeping Dormant Entities Active," American Health Law Association, December 19, 2024
- Named to “Georgia Trend’s Legal Elite,” Taxes/Estates/Trusts, 2024