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GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era
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GuideStar Webinar (02/15/11) - Grantmaker Due Diligence in the Pension Protection Act Era

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  • 1. Grantmaker Due Diligence in the Pension Protection Act Era: How to identify supporting organizations and align your grants administration process with the 21st century tax code 15 February 2011 1© 2011, GuideStar USA, Inc. All Rights Reserved. This information is copyrighted subject matter owned byGuideStar USA and is protected by United States and international copyright law.
  • 2. Today’s FacilitatorsPamela JowdySenior Product Manager, GuideStarSuzanne Ross McDowellPartner, Steptoe & Johnson, LLP 2
  • 3. Participant Poll #grantmakerdd 3
  • 4. Today’s Objectives1. Internal Revenue Code: Impacts on Grantmakers  Why Verify: Pension Protection Act of 2006  Supporting Organizations: Relationships and Control  Expenditure Responsibility: Defined  Due Diligence: Methods and Best Practices2. GuideStar Charity Check: Anatomy of a Solution  How it works  What it delivers  Why it works3. “Automatic” Failure to File Revocations4. Q & A 4
  • 5. Internal Revenue CodeImpact of the Pension Protection Act of 2006 onGrantmakersSuzanne Ross McDowellPartnerSteptoe & Johnson LLPsmcdowell@steptoe.com 5 #grantmakerdd
  • 6. Summary ofPension Protection Act Provisions Affecting Grants to Supporting Organizations #grantmakerdd 6
  • 7. Changes Made by thePension Protection Act of 2006 Private Foundations (PFs)  Grants to certain supporting organizations (SOs) do not count towards minimum distribution • Penalty: 30% of shortfall; must make correction  Grants to certain SOs require expenditure responsibility • Penalty: 20% of grant on foundation; potentially 5% on directors and officers; must make correction Donor Advised Funds (DAFs)  Grants to certain SOs require expenditure responsibility • Penalty: 20% of grant on sponsor of DAF 7
  • 8. What is a Supporting Organization? Internal Revenue Code provides--  All 501(c)(3) organizations are either private foundations or public charities  Private foundations are subject to greater regulation Public charities include:  Schools, hospitals, churches, government units  Organizations that meet specific requirements for broad public support  SOs All other 501(c)(3) organizations are private foundations 8
  • 9. What is a Supporting Organization?(cont’d) SO is a 501(c)(3) organization which is--  Classified as a public charity (not a PF)  Because it has a specified relationship with another public charity (the supported organization) Types of relationships  Type I – Parent-subsidiary  Type II – Brother-sister  Type III – Operated in connection with • Functionally Integrated • Not Functionally Integrated 9
  • 10. Which Supporting OrganizationsRequire Expenditure Responsibility? Type III Non-Functionally Integrated SOs All other SOs if--  A disqualified person of the foundation making a grant to the SO directly or indirectly controls the SO or a supported organization; or  A donor to a DAF, or a person designated by the donor to advise with respect to distributions, directly or indirectly controls a supported organization #grantmakerdd 10
  • 11. What is Expenditure Responsibility? Procedures designed to ensure that PF funds are used for exclusively charitable purposes--  Pre-grant inquiry  Written grant agreement with the grantee  Grantee must keep funds separate from noncharitable funds  Regular reports from the grantee to PF  PF reports to IRS on Form 990-PF that expenditure responsibility requirements were met 11
  • 12. Which Grants Do Not Count Toward aPrivate Foundation’s MinimumDistribution?Grants to-- Type III Non-Functionally Integrated SOs All other SOs if--  A disqualified person of the foundation making a grant to the SO directly or indirectly controls the SO or a supported organization 12
  • 13. When Does a Person Have Control? No IRS guidance provides clear method for determining whether control exists. Control exists when one or more disqualified persons or donors may, by aggregating their votes or positions of authority, require the SO or supported organization to make an expenditure, or prevent the SO or supported organization from making an expenditure. See Notice 2006-109. 13
  • 14. When is a Type III SupportingOrganization Functionally Integrated? Proposed Regulations issued on September 24, 2009 Until temporary or final regulations are issued, can rely on Notice 2006-109 or Proposed Regulations  Notice 2006-109: SO is functionally integrated • When the activities engaged in for or on behalf of a supported organization(s) are activities to perform the functions of, or to carry out the purposes of, such organization(s), and; • But for the involvement of the SO, would normally be engaged in by the supported organization(s) themselves. 14
  • 15. When is a Type III SupportingOrganization Functionally Integrated?(cont’d) Proposed Regulations: SO is functionally integrated  If engages in activities substantially all of which directly further the exempt purposes of the supported organization(s), by performing the functions of or carrying out the purposes of the supported organization(s); and  But for the involvement of the SO, would normally be engaged in by the supported organizations  Includes owning and managing exempt-use property  Does not include fundraising or managing non- exempt use property for a supported organization  Special rules for hospitals and governmental units 15
  • 16. Conducting Due Diligence to Avoid Excise Taxes under the Pension Protection Act #grantmakerdd 16
  • 17. Step 1: Determine if PotentialGrantee is a 501(c)(3) Organization Approved Methods  IRS Determination Letter; and  Verification of listing in IRS Pub. No. 78 • Pub. No. 78 Weekly Updates in Internal Revenue Bulletin If grantee is not a 501(c)(3), no new rules If grantee is a 501(c)(3), must determine if it is an SO 17
  • 18. Step 2: Determine if PotentialGrantee is a SO Approved Methods  IRS Determination Letter • Section 509(a)(1) and 509(a)(2) organization – not a SO • Section 509(a)(3) organization = SO • IRS letter may be silent  IRS Business Master File • Direct access (Notice 2006-109) • Access to IRS BMF data through third party such as GuideStar (Rev. Proc. 2009-32) If grantee is not a SO, can make grant—no new rules If grantee is a SO, must determine the type 18
  • 19. Step 3: If Grantee is a SO, Determinethe Type of SO Method 1: IRS Determination Letter  Most Determination Letters don’t include Type • Prior to 2006, no need for Type  Prior to February 22, 2007, IRS issued Determination Letters on FI status based on an Advance Notice of Proposed Rulemaking (ANPRM)  ANPRM superseded by Prop. Reg. but can continue to rely on Determination Letter issued under ANPRM until Prop. Reg. are issued as temporary or final as long as SO meets the requirements of ANPRM or Prop. Reg.  IRS now issuing Determination Letters that a Type III is Functionally Integrated under Prop. Reg. definition 19
  • 20. Step 3: If Grantee is a SO, Determinethe Type of SO (cont’d) Method 2:  Reasoned written opinion of counsel of PF or DAF 20
  • 21. Step 3: If Grantee is a SO, Determinethe Type of SO (cont’d) Method 3:  Good Faith Reliance on Written Representation by Grantee • Representation by officer, director or trustee • Describes how officers, directors and trustees of grantee are selected • For Type I or II, references governing document provisions establishing relationship with supported organization • For Type III-- identifies supported organizations 21
  • 22. Step 3: If Grantee is a SO, Determinethe Type of SO (cont’d)Method 3 (cont’d)  Review by PF or DAF • Governing documents of SO and supported organization • For Type III, representation from supported organizations o Re types of activities o That, but for SO, supported organization would conduct activities of SONote: cannot rely on Form 990 to determine Type 22
  • 23. Step 3: If Grantee is a SO, Determinethe Type of SO (cont’d) If grantee is a Non-Functionally Integrated Type III SO, then PF or DAF must exercise expenditure responsibility and grant does not count toward non-operating foundation’s minimum distribution If grantee is a Type I, Type II or Functionally Integrated Type III SO, must determine if a disqualified person of a PF or donor or donor’s designee of a DAF has control 23
  • 24. Step 4: Determine if Disqualified Personor Donor has Control over SO orSupported Organization No IRS approved procedure; use definition in Notice 2006-109 Obtain list of supported organization(s) Identify disqualified persons for a PF and donors and their designees for a DAF Determine if disqualified persons exercise control over SO or supported organization Determine if donors/designees control supported organization Direct or indirect control 24
  • 25. Step 4: Determine Control (cont’d) If disqualified person or donor (or donor’s designee) has control, then must exercise expenditure responsibility and grant does not count toward a non-operating foundation’s minimum distribution 25
  • 26. Summary Type III which is Not Functionally Integrated  Grant does not count toward non-operating foundation’s minimum distribution  PFs and DAFs must exercise expenditure responsibility Type I, II or Functionally Integrated Type III with disqualified person or donor control  Grant does not count toward non-operating foundation’s minimum distribution  PFs and DAFs must exercise expenditure responsibility #grantmakerdd 26
  • 27. GuideStar Charity CheckAnatomy of a SolutionPamela JowdySenior Product Manager #grantmakerdd 27
  • 28. Why Verify?The Challenge: Recap Two Unique Due Diligence To-Do’s:To-Do: Data Source: Verify Current Publication 78 Charitable Status and Internal Revenue Bulletin Identify Supporting Organizations with IRS Business Master File 509(a)(3) status #grantmakerdd 28
  • 29. Why Verify: IRS Data SourcesPub 78 and Internal Revenue Bulletin Establish Tax Deductibility and Verify Current Charitable Status IRS Publication 78:  Also known as Cumulative List of Organizations  Includes all organizations to which charitable contributions are tax deductible  Current tax-exempt status, percentage of contributions that are tax deductible  Deductibility limitations  Published quarterly IRS Internal Revenue Bulletin:  Also known as the „IRB‟  Lists organizations whose charitable status has been changed or revoked  Updated weekly Rev. Proc. 82-39, 1982-1 C.B. 759 Sec.3.01 and Sec.3.02 states that grantors “may rely on the classification of an organization listed in or covered by Publication No. 78.” #grantmakerdd 29
  • 30. Why Verify: IRS Data SourcesIRS Business Master File Determine 509(a) Status IRS Business Master File:  Lists all tax-exempt organizations registered with the IRS  Published monthly  Includes reason for non-private foundation status, aka “public charity classification”  Reason for non-private foundation status = 509(a) status 509(a)(1) and 509(a)(2):  A public charity that receives a substantial amount of public support to fund its operations 509(a)(3): Supporting Organization  A public charity that provides support to one or more publicly supported organizations  Must demonstrate that is has a particular type of relationship with the organization it supports #grantmakerdd 30
  • 31. Why Verify: Pension Protection ActSupporting Organizations Snapshot IRS Business Master File 509(a) Universe IRS Business Master File 32,191 509(a)(3) Supporting Organizations: 509(a)(3) 4%  21,505 have filed a form 990 509(a)(2)  4% of all 509(a) orgs 28% 12,305 of the 32,000 largest foundations, or 38%, made a grant to any supporting organization between 2000 and 2004 509(a)(1) 68% While the supporting organization universe is fairly discrete, failure to identify these organizations creates an exponentially greater fiscal and operational risk for private foundations and sponsors of donor-advised funds. #grantmakerdd 31
  • 32. Internal Revenue Code Charity Check v1.5 100% compliant withGrants Administration Milestones IRS FAQ and Revenue Procedure 2009-32 1969 August December March June 2006 2006 2007 2009 Internal Revenue Code Tax Reform Act Pension Protection Interim Guidance IRS FAQ on IRS Revenue Act Regarding Business Master File Procedure 2009-32The legal framework Supporting Orgs Reliancefor the regulation of New requirements on and Donor-Advised Formalizes March private foundations grants to certain Funds Allows grantors to use 2007 FAQand public charities supporting third party resources is established organizations Grantor may rely on to obtain required IRS Precedential [509(a)(3)] IRS BMF or Letter of BMF information instrument upon Determination for about a potential which compliance Definition of Type III identifying supporting grantee‟s charity and grantmaking supporting organization 509(a) classification under teams can rely organizations status section 509(a)(1), (2) or (3) Definition of Type III functionally integrated supporting organizations 32
  • 33. Why Verify: Pension Protection ActIRS Revenue Procedure 2009-32 June 2009 Source: http://www.irs.gov/pub/irs-drop/rp-09-32.pdf #grantmakerdd 33
  • 34. GuideStar Charity CheckAn Integrated, One-Stop Verification Solution How it Works Incorporates Weekly Internal Revenue Bulletin Marries Publication 78 data with IRS Business Master File data  Married, but never modified OFAC verification included (organization level) 10 year track record of consuming and managing IRS data #grantmakerdd 34
  • 35. GuideStar Charity CheckAn Integrated, One-Stop Verification Solution What it Delivers Date and time stamp Electronic or hard copy documentation Verify Current Charitable Status Latest Quarterly Pub 78 Weekly Bulletin Date EIN Identify IRS BMF Date Supporting OrganizationsReason for Non-Private with 509(a)(3) Foundation Status status 35
  • 36. GuideStar Charity CheckAn Integrated, One-Stop Verification Solution Why it WorksFully compliant with recently issued guidance from IRS concerning reliance on third-party resources for IRS BMF data: The grantees‟ name, EIN and public charity classification (aka “reason for non-private foundation status”) under section 509(a)(1), (2) or (3) is presented in the report A statement that the information in the report is from the most currently available IRS monthly update to the BMF, along with the IRS BMF revision dateThe date and time of the grantor‟s search is included on the report The third party IRS BMF data and report must be in a form which the grantor can store in hard copy or electronically. 36
  • 37. Recap #grantmakerdd 37
  • 38. Charity Check User ExperienceTwo Clicks to Compliance Pamela Jowdy Senior Product Manager GuideStar #grantmakerdd 38
  • 39. Common Participant Questions1. IRS Data Sources: Manual Verification Options  Publication 78  Internal Revenue Bulletin  Business Master File2. The Letter of Determination: isn’t this good enough? #grantmakerdd 39
  • 40. IRS Publication 78Grantmaker Verification Options IRS Publication 78 Online  IRS website provides search functionality for Pub 78  Does not include IRB weekly updates; must search separately for changes and / or revocations  Cannot search by EIN  No date or time stamp 40Source: http://apps.irs.gov/app/pub78
  • 41. IRS Internal Revenue BulletinGrantmaker Verification Options IRS IRB Includes status changes and revocations Published weekly in pdf and html format Does not include EIN Not searchable Source: http://www.irs.gov/irb 41
  • 42. IRS Business Master FileGrantmaker Verification Options IRS Downloadable Business Master File Draft of manual solution for 509(a)verification directly from IRS BMF #grantmakerdd 42
  • 43. The Letter of DeterminationIsn’t this good enough? What it is Static, historic snapshot Only accurate at time of issuance Confirms 501c3 status What it is NOT Does not account for changes in charitable status since date of original issuance Some letters include SO Type (2006) IRS suspended letters for Type III functionally integrated SOs 2.22.07 Does not reflect automatic revocations starting in 2011 43
  • 44. Automatic RevocationsFailure to file annual return for 3 consecutive years Pension Protection Act of 2006 provision Forms 990-N, 990-EZ, 990 or 990-PF Religious organizations are still exempt from filing requirement GuideStar estimates 350,000 NPOs may be at risk Many NPOs with annual gross revenues < $25K previously not required to file; now must file 990-N First deadline: 5.17.10 for NPOs with FYE date of 12.31.09  IRS granted “temporary relief” extension until 10.15.10 “At Risk” Organizations: www.irs.gov/thelist 44
  • 45. Automatic RevocationsFailure to file annual return for 3 consecutive years IRS to publish list early 2011 Publication will be ongoing and updated monthly GuideStar working closely with IRS to understand timing, data structure and distribution model into BMF GuideStar Charity Check will include a flag for these “failure to file” organizations GuideStar Premium will include a flag for these “failure to file” organizations 45
  • 46. Questions Already Submitted1. International Grantmaking2. Supporting Organization Type and Charity Check3. Advance Ruling Process and Charity Check4. OFAC: Definition and options5. XML Delivery Options #grantmakerdd 46
  • 47. International GrantmakingConsiderations Does the foreign charity already have a Letter of Determination? Exercise expenditure responsibility Equivalency Determination International Repository Project:  www.USIG.org [COF-sponsored website]  www.ngosource.org [international repository project website] Become familiar with the USA Patriot Act #grantmakerdd 47
  • 48. Supporting Organization TypesOptions and Approaches Supporting Organization Guidesheets published by IRS GuideStar Charity Check policy and long term product vision http://www.irs.gov/charities/article/0,,id=174956,00.html Consult your legal counsel! 48
  • 49. Advance Ruling ProcessTemporary IRS Regulations Issued September 9, 2008 Eliminated the advance ruling process for 501(c)(3) organizations reasonably expected to be publically supported IRS automatically classifies new 501(c)(3)s as public charities for first 5 years if can reasonably be expected to be publically supported Includes public charities whose advance ruling period has not yet expired or expired after June 9, 2008 Charity Check still publishes the Advance Ruling date in the body of the report, where applicable Footer messaging and link to IRS resource persists 49 http://www.irs.gov/charities/charitable/article/0,,id=185568,00.html
  • 50. OFAC and SDNDefinition and Options Office of Foreign Assets Control / Specially Designated Nationals  http://www.ustreas.gov/offices/enforcement/ofac/Source: Technology Affinity Group and Council on Foundations‟ 2007 Grantmakers Information Technology Report, September 2007 #grantmakerdd 50
  • 51. Charity Check Web ServiceXML* Data and PDF Report Delivery *Extensible Markup Language = easy way to share structured data via ether 51
  • 52. 52
  • 53. Contact Informationwebinars@guidestar.orgSuzanne Ross McDowellPartner, Steptoe & Johnson, LLPsmcdowell@steptoe.com #grantmakerdd 53
  • 54. Appendix 54
  • 55. GuideStar Charity CheckAccess Points: Results #grantmakerdd 55
  • 56. GuideStar Charity CheckAccess Points: Report 56
  • 57. GuideStar Charity Check509(a)(3) Supporting Organization 57
  • 58. GuideStar Charity CheckNot Verified in Publication 78 58
  • 59. GuideStar Charity CheckNot Listed in IRS Business Master File 59
  • 60. GuideStar Charity CheckOFAC Organization: Results 60
  • 61. GuideStar Charity CheckOFAC Organization: Report 61
  • 62. Grantmaker Due Diligence in the Pension Protection Act Era: How to identify supporting organizations and align your grants administration process with the 21st century tax code© 2011, GuideStar USA, Inc. All Rights Reserved. This information is copyrighted subject matter owned byGuideStar USA and is protected by United States and international copyright law. 62

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