TY 2020 GeneralExplanationAttachment
Name:
ONE8 FOUNDATION
EIN:
04-6836735
Identifier Return Reference Explanation
CONTRIBUTIONS FORM 990-PF CONTRIBUTIONS TO ONE8 FOUNDATION BY INDIVIDUALS ARE SUBJECT TO THE 60% AGI LIMITATION (100% FOR 2020), AS ONE8 FOUNDATION QUALIFIES AS A PRIVATE FOUNDATION DESCRIBED IN IRC SECTION 170(B)(1)(A)(VII) AND (F)(II), AS THE FOUNDATION:1. MADE DISTRIBUTIONS IN AN AMOUNT EQUAL TO 100% OF THE CONTRIBUTIONS RECEIVED IN THE FOUNDATION'S TAX YEAR, NOT LATER THAN THE 15TH DAY OF THE THIRD MONTH AFTER THE CLOSE OF SUCH TAXABLE YEAR.2. SUCH DISTRIBUTIONS ARE QUALIFYING DISTRIBUTIONS.3. SUCH DISTRIBUTIONS ARE TREATED AS MADE OUT OF CORPUS.4. HAS NO REMAINING UNDISTRIBUTED INCOME FOR 2020 , OR ANY SUCH PRIOR YEAR.ONE8 FOUNDATION HEREBY ELECTS, PURSUANT TO TREASURY REGULATIONS SECTIONS 1.170A-9(H) AND 53.4942(A)-3(C)(2), TO TREAT DISTRIBUTIONS OF $13,000,000 (WHICH EQUALS THE VALUE OF ALL CONTRIBUTIONS RECEIVED IN 2020), FROM JONATHON AND JOANNA JACOBSON, AS DISTRIBUTIONS OUT OF CORPUS. PURSUANT TO REG. 53.4942(A)-3(C)(2)(IV), ONE8 FOUNDATION HEREBY ELECTS TO TREAT, AS A CURRENT CORPUS DISTRIBUTION, THE FOLLOWING UNUSED PRIOR TAX YEAR'S DISTRIBUTIONS THAT WERE TREATED AS CORPUS DISTRIBUTIONS UNDER REG. 53.4942(A)-3(D)(1)(III) IN SUCH PRIOR TAX YEARS:TAX YEAR:2015: $3,796,1352016: $5,083,5942017: $3,713,7522018: $406,519
INTEREST EXPENSE FORM 990-PF, PART I, LINE 17 INTEREST EXPENSE IS DERIVED SOLELY FROM THE ORGANIZATION'S PASS-THROUGH INVESTMENT ACTIVITIES.