Douglas N. Varley

Douglas N. Varley is a Member of Caplin & Drysdale's Washington, D.C., office. He became a Member of the firm in February, 2000.

Services

Mr. Varley's practice focuses principally on advising exempt organizations, in particular, private foundations. He has guided the design of major grantmaking programs and participated in the development of national public educational campaigns targeted on a range of significant policy issues. In addition to helping a diverse array of nonprofit organizations comply with the rules governing lobbying and political activities, his areas of concentration also include such matters as international philanthropy, restrictions on executive compensation, transactions with for-profit organizations, and minimizing unrelated business income tax. Before embarking on his legal career, Mr. Varley administered grantmaking programs for college and university faculty at the National Endowment for the Humanities.

Professional Activities

Mr. Varley has served on the Board of Trustees of several national nonprofit organizations, including the National Audubon Society, the NRDC Action Fund, and Earthjustice. He is an Adjunct Professor at Georgetown University Law Center.

Awards & Rankings

• The Legal 500, Leading Lawyer, 2011 and 2013; Recommended, 2014-2017
• Best Lawyers in America, Lawyer of the Year, 2021; 2013-Present
• American Bar Association Outstanding Nonprofit Lawyer, 2019

Recent News

• Caplin & Drysdale Earns Top Ranking in 2021 "Best Lawyers in America", U.S. News & World Report, August 20, 2020
• Douglas Varley Weighs in on Lawsuit Filed Against the NRA, NPR WAMU, August 6, 2020
• Douglas Varley Speaks to Washington Post on NRA Lawsuit, The Washington Post, August 6, 2020
• Douglas Varley and Meghan Biss Comment on Salt Lake Tribune Becoming a 501(c)(3), Associated Press, November 29, 2019
• Douglas Varley Comments on Loans by Nonprofits in Washington Post, The Washington Post, September 7, 2019
• Douglas Varley Receives Outstanding Nonprofit Lawyer Award, American Bar Association, August 20, 2019
• Caplin & Drysdale Attorneys Listed as "Best Lawyers In America", August 15, 2019
• Douglas Varley Talks to The Washington Post on NRA's Tax Exempt Status, The Washington Post, August 6, 2019
• Doug Varley Speaks to The Washington Post on the NRA's Federal and State Filings, The Washington Post, June 9, 2019
• Douglas Varley Comments on Nonprofits' Political Activity, Institutional Investor, April 23, 2019
• ABC News Quotes Douglas Varley on Potential IRS Red Flags for Trump Charitable Transactions, ABC News, February 28, 2019
• Douglas Varley Discusses Key Issues for General Counsel of International Nonprofits at Directors Roundtable Event, The Directors Roundtable, January 22, 2019
• Caplin & Drysdale Improves Ranking in 2019 "Best Lawyers in America", August 15, 2018
• Douglas Varley Comments on New Tax-Exempt Donor Rule, MLex US Tax Watch, July 27, 2018
• Bloomberg Quotes Douglas Varley: Government Settles Two Tea Party Suits Over IRS Targeting, Bloomberg Law, October 27, 2017
• Caplin & Drysdale Earns Top Ranking in 2018 "Best Lawyers in America", August 15, 2017
• 18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking, The Legal 500, June 2, 2017
• Best Lawyers in America Lists 18 Caplin & Drysdale Attorneys, U.S. News & World Report, August 15, 2016
• Bloomberg BNA Quotes Doug Varley on New IRS Rules for Nonprofits, Bloomberg BNA, July 9, 2016
• Caplin & Drysdale Recognized for Cutting Edge Advice, The Legal 500, June 16, 2016
• Caplin & Drysdale Named Top Tier Firm for Tax Controversy, June 8, 2015
• Caplin & Drysdale Lawyers Earn Best Lawyers Ranking, August 21, 2014
• Clients and Peers Recommend Caplin & Drysdale in 2014 Legal 500 Ranking, The Legal 500, July 1, 2014
• Tax Directors Handbook Recommends Caplin & Drysdale As A Leading Tax Law Firm, Tax Directors Handbook, December 19, 2013
• 19 Caplin & Drysdale Attorneys Achieve Best Lawyers in America Ranking, U.S. News & World Report, October 21, 2013
• The Legal 500 Recommends Caplin & Drysdale As a Leading Firm For 2013, The Legal 500, June 3, 2013
• 2012 Tax Directors Handbook Ranks Caplin & Drysdale as Leading Tax Law Firm, Tax Directors Handbook, December 1, 2011
• Chambers and Legal 500 Recognize Caplin & Drysdale in 2011 Top Rankings, Chambers USA / The Legal 500, June 16, 2011
• Douglas Varley Joins Audubon Board, National Audubon Society, May 17, 2011
• Douglas Varley Is Quoted in Bloomberg on AARP's Tax Exempt Status, Bloomberg, March 30, 2011
• Douglas Varley Appointed as Member of the Special Task Force on Fiscal Oversight, PR Newswire, September 21, 2010
• Cancer Fighter, The National Law Journal, January 25, 2010

Click here for a full list of media coverage.

Speaking Engagements

• Panelist, Fifty Years after the 1969 Tax Act: Reflecting on the History and Future of Private Foundations, The Andrew W. Mellon Foundation, November 20, 2019
• Panelist, World Recognition of Distinguished General Counsel: Honoring Joshua Mintz & the Law Department of the MacArthur Foundation, The Directors Roundtable, October 24, 2018
• Panelist, Managing Complex Grantmaking Issues, 2018 Representing and Managing Tax-Exempt Organizations, Georgetown University Law Center, April 27, 2018
• Panelist, Advocacy Outside the United States, American Bar Association Section of Taxation 2018 Midyear Meeting, February 9, 2018
• Panelist, Advanced Self-Dealing Issues, 33rd Annual Representing and Managing Tax-Exempt Organizations, Georgetown University Law Center, April 29, 2016
• Panelist, Private Foundations: Special Self-Dealing Problems, American Bar Association, 2015 Midyear Meeting, January 30, 2015
• Speaker, Washington Update - Nonprofit, Dallas CPA Society, Convergence 2013, May 8, 2013
• Panelist, Foundations: Lobbying Is Not a Dirty Word, Georgetown Law Center, Issues in Nonprofit Governance, April 24, 2013
• Panelist, Private Foundations: Practical Considerations in Addressing Excise Tax Consequences, American Bar Association, 2012 Joint Fall CLE Meeting, September 14, 2012
• Panelist, The Rationale and Ripple Effects of Citizens United v. FEC, Caplin & Drysdale, Audio Conference, January 29, 2010
• Speaker, On the Horizon: Current Developments in Nonprofit Governance and Advocacy, Grant Thornton and Caplin & Drysdale, November 17, 2009
• Chair, Twelfth Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, American Law Institute (ALI), American Bar Association, October 1, 2009

Click here for a full list of speaking engagements.

Recent Publications

• "IRS Proposes Regulations on UBTI Siloing; Comments Due Soon," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 28, 2020
• "UPDATE: CARES Act Assistance for Nonprofit Employers: Retention Credits and Tax Deferral," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 13, 2020
• "IRS Extends the Deadline for Exempt Organizations to File Federal Tax Returns," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 10, 2020
• "CARES Act Assistance for Nonprofit Employers: Update on Loans to Larger Nonprofits," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 10, 2020
• "CARES Act Assistance for Nonprofit Employers: Loans, Emergency Grants and Other Assistance," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 3, 2020
• "UPDATE: CARES Act Assistance for Nonprofit Employers: Paycheck Protection Loans and Loan Forgiveness," with William M. Klimon, Meghan R. Biss, William D. Fournier, and Amanda Reed, Caplin & Drysdale Client Alert, April 3, 2020
• "Update on Nonprofit Donor Disclosure Requirements: IRS Tries Again," with William D. Fournier, Sharon P. Want, Meghan R. Biss, and William M. Klimon, Caplin & Drysdale Client Alert, September 10, 2019
• "Update on Nonprofit Donor Disclosure Requirements," with William D. Fournier, Sharon P. Want, Meghan R. Biss, and William M. Klimon, Caplin & Drysdale Client Alert, August 1, 2019
• "U.S. Supreme Court Denies Request for Stay of Ruling Requiring Nonprofit Donor Disclosure," with Trevor Potter, Matthew T. Sanderson, Sharon P. Want, and Bryson B. Morgan, Caplin & Drysdale Client Alert, September 19, 2018
• "IRS Issues Guidance on Calculating Unrelated Business Income Tax," with Meghan R. Biss, William D. Fournier, and Sharon P. Want, Caplin & Drysdale Client Alert, August 23, 2018
• "Federal District Court Vacates FEC Independent Expenditure Donor Disclosure Rule; Appeal Likely," with Trevor Potter, Matthew T. Sanderson, Sharon P. Want, and Bryson B. Morgan, Caplin & Drysdale Client Alert, August 9, 2018
• "IRS Donor Disclosure Requirements Eliminated for Most Nonprofit Organizations," with William D. Fournier, Sharon P. Want, Meghan R. Biss, and William M. Klimon, Caplin & Drysdale Client Alert, July 17, 2018
• "IRS Guidance Removes Obstacle to Restructuring Tax-Exempt Organizations," with Meghan R. Biss, William M. Klimon, and Sharon P. Want, Caplin & Drysdale Client Alert, March 8, 2018
• "New IRS Procedures Will Impact Nonprofits," with Sharon P. Want, Meghan R. Biss, and William D. Fournier, Caplin & Drysdale Client Alert, January 25, 2018
• "New York Passes New Legislation Affecting Political Activity at the Local and State Level," with Trevor Potter and Matthew T. Sanderson, Caplin & Drysdale Client Alert, July 5, 2016
• "IRS Releases Final Foreign Grantmaking Regulations," with Sharon P. Want, Caplin & Drysdale Client Alert, September 29, 2015
• "Letter to DOJ Confirms IRS Intent to Resume Church Tax Inquiries," with William M. Klimon, Caplin & Drysdale Client Alert, August 7, 2014
• "New York Adopts Substantial Changes to Laws Regulating Nonprofits," with William M. Klimon and William D. Fournier, Caplin & Drysdale Client Alert, December 20, 2013
• "Wisconsin Court Holds Parsonage Allowance Unconstitutional," with William M. Klimon and William D. Fournier, Caplin & Drysdale Client Alert, November 27, 2013
• "Washington Post Releases Database of Reported Nonprofit Asset Diversions," with William M. Klimon and William D. Fournier, Caplin & Drysdale Client Alert, October 30, 2013
• "Stalled Applications for Section 501(c)(3) Status: Is it Time to Sue the IRS?," with William M. Klimon and William D. Fournier, Caplin & Drysdale Client Alert, August 16, 2013
• "Exempt Organizations News Flash: Priority Guidance Plan," Caplin & Drysdale Client Alert, August 12, 2013
• "Exempt Organizations News Flash: IRS Updates," Caplin & Drysdale Client Alert, June 28, 2013
• "Summary of New York's New Political Disclosure Rules for Nonprofits," with Matthew T. Sanderson, Trevor Potter, William M. Klimon, and Bryson B. Morgan, Caplin & Drysdale Client Alert, June 21, 2013
• "Lessons Learned From the IRS Colleges & Universities Compliance Project," Caplin & Drysdale Client Alert, June 4, 2013
• "IRS Issues Priority Guidance Plan," Caplin & Drysdale Client Alert, November 21, 2012
• "IRS Issues New Regulations for Foreign Grantmaking by Private Foundations," Caplin & Drysdale Client Alert, October 3, 2012
• "IRS Confirms Deductibility of Contributions to Domestic Disregarded Entities," with William M. Klimon and William D. Fournier, Caplin & Drysdale Client Alert, August 3, 2012
• "Recent Developments," Caplin & Drysdale Client Alert, February 21, 2012
• "The Gift Tax and Contributions to Section 501(c)(4) Organizations," with Matthew T. Sanderson, Trevor Potter, and Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, July 11, 2011
• "The Gift Tax and Contributions to Section 501(c)(4) Organizations: Less than Meets the Eye?," with Matthew T. Sanderson, Trevor Potter, and Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, June 14, 2011
• "IRS Articulates New Standards for Nonprofit Websites," Caplin & Drysdale Client Alert, February 27, 2009
• "Federal Tax Laws Affecting Political Activity and Lobbying by Tax-Exempt Charitable Organizations," Political Activity, Lobbying Laws and Gift Rules Guide, January 1, 2008
• "Teaching Taxation: Following the Money in the 2000 Election," The Exempt Organization Tax Review, December 1, 2000

Click here for a full list of publications.