Timothy Schnabel (Yale, Class of 2005) has published Vigilante Nonprofits:  The Bob Jones Rule as Applied to the International Promotion of the Rule of Law, 24 Va. Tax Rev. 921 (2005).  Here is part of the Introduction:

[M]any … [nonprofit] organizations based in this country have motives and missions such as distributing Bibles or freeing slaves that Americans would consider laudable and charitable if carried out within the United States but that run afoul of the laws of the governments in whose territories they operate.  What are the legal consequences when an American nonprofit operating abroad begins to act like a vigilante, promoting its own allegedly charitable agenda despite the prohibitions of foreign laws?  The Supreme Court has held that an organization that violates a fundamental federal public policy is not charitable and is thus not eligible for tax exemption.  The fundamental policy addressed by the Court was a domestic one:  the elimination of racial discrimination in education.  Should the loss of exemption rule also apply to a different fundamental policy — the goal of promoting the growth of the rule of law — that operates in the international sphere?  An organization that violates another country’s laws undermines the rule of law ideal that the law ought to bind everyone equally and effectively; should such an organization still be granted tax-exempt status?