Stephanie R. Hoffer (Northwestern) has published A Comparison of Tax Exempt Organizations in the People’s Republic of China and the United States, 3 Loy. U. Chi. Int’l L. Rev. 1 (2005).  Here is part of the Introduction:

Both the United States and China are on the cusp of major changes in governmental regulation of charitable organizations. As China moves forward with the marketization of its socialist economy, the use of nonprofit organizations for both mediation and alleviation of market failure has become increasingly important. Toward that end, China’s State Council has enacted a law describing the role and governance of charitable foundations in China. The United States, on the other hand, has a fully developed charitable law, but it is one that the government has considered amending to discourage instances of fraud and self-dealing that have recently come to light. This article seeks to compare and contrast the two systems with an eye toward informing the work of scholars and policy-makers interested in the governance of charitable organizations.