[Foundation-l] Mission & Vision statement updated

[Anthony]

On 4/26/07, Thomas Dalton <thomas.dalton at gmail.com> wrote:
> > > Just a quick point here: the Foundation may not change its mission  statement
> > > without an official determination letter from the IRS.
> >
> > Can you please provide us with the law or regulation which says this?
> > Can you also let us know the methods by which one can obtain such a
> > determination letter?  Are you saying an entirely new Form 1023 has to
> > be submitted?
>
> I don't know the details, but it is common sense that such a law
> exists.

Some more information, from the IRS website:
http://www.irs.gov/charities/charitable/article/0,,id=123213,00.html

"The IRS will rule on the tax consequence of proposed changes to an
organization's purposes or activities. Thus, if you are unsure about
whether proposed changes are consistent with your status as an exempt
organization or as a public charity (if applicable), you may want to
request a private letter ruling or determination letter."

"In some areas, the law requires that an organization notify the
Internal Revenue Service or receive an advance determination before
undertaking a transaction resulting in certain tax consequences."

A list of activities follows.  Rather than quote them all, if you're
interested you can go to that link.  The revenue procedure at
http://www.irs.gov/pub/irs-tege/rp2007-4.pdf is also fun reading.
I'll leave it up to you to decide how to apply this to the
foundation's situation, rather than pull out all those fun disclaimers
about how this is not a covered opinion.

Anthony