Decker, The Steward’s Mandate Building Church-Controlled Investment Funds Without Compromising Mission or Status
This thesis presents the first comprehensive legal framework enabling churches to lawfully own and operate investment funds without forfeiting their 501(c)(3) tax-exempt status. Amid rising fiscal instability and declining traditional tithing, many churches have begun exploring enterprise-backed models of financial resilience. Yet no doctrinal architecture has previously been constructed to guide religious institutions in navigating this complex intersection of passive investment, nonprofit law, and theological integrity.
The Steward’s Mandate introduces and defines Sanctified Capital as a distinct, legally compliant category of exempt-function revenue: capital generated through church-controlled entities structured under federal tax law, governed for the exclusive advancement of religious purposes. The thesis synthesizes the Internal Revenue Code (particularly §§501(c)(3), 511–514), Treasury Regulations, IRS enforcement doctrine, and controlling case law including Redlands Surgical Services, Rev. Rul. 98-15, and American Bar Endowment, to construct a legally defensible governance model that withstands scrutiny under both UBIT doctrine and constitutional neutrality principles (per Walz, Swaggart, and Bob Jones).
It is the first academic work to codify a firewall governance model tailored for churches, leveraging entity structure, fiduciary oversight, passive income classification, and mission-aligned policy clauses to segregate commercial operations from ecclesial purpose. It also reframes 501(c)(3) governance as a covenantal stewardship mandate, integrating fiduciary law with biblical principles of trust, multiplication, and open-handed governance.
Further, this thesis breaks new ground by offering the first full legal analysis of equity gifts to churches as a compliant and tax-efficient alternative to traditional tithing. It outlines the procedural requirements for valuation, donor substantiation, passive income exclusion, and anti-inurement compliance—transforming theoretical generosity into practical doctrine.
What emerges is not a proposal for regulatory change, but a doctrinal clarification: the IRS already permits what churches have lacked the confidence, language, and legal structure to pursue. The Steward’s Mandate provides that structure. It empowers religious organizations to steward enterprise within legal and theological boundaries—producing mission-aligned capital that is not just lawful, but sanctified.
Lloyd Mayer