[Foundation-l] Mission & Vision statement updated

Ray Saintonge saintonge at telus.net
Fri Apr 27 06:42:12 UTC 2007

Anthony wrote:

>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
>Some more information, from the IRS website:
>"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."
One point that came up earlier about 501(c)(3)'s had to do with the 
distribution of assets in the event of dissolution.  It was stated at 
that time that the distribution had to be to another 501(c)(3) in the 
United States.  After looking at that section in the code and the 
regulations I find nothing that says that the assets must go to an 
organization in the United States.  It appears sufficient that the 
receiving organization be use them for putposes outlined in 501(c)(3).


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