TY 2021 GeneralExplanationAttachment
Name:
RAIKES FOUNDATION
EIN:
91-2173492
Identifier Return Reference Explanation
OUT OF CORPUS ELECTION FORM 990-PF, PART XII, LINE 7 ELECTION UNDER REGS. SECTION 53.4942(A)-3(D)(2) TO TREAT EXCESS QUALIFYING DISTRIBUTIONS AS DISTRIBUTIONS OUT OF CORPUS.PURSUANT TO INTERNAL REVENUE CODE SECTION 4942(H) AND TREASURY REGULATIONS SECTION 53.4942(A)-3(D)(2), THE TAXPAYER HEREBY ELECTS TO TREAT $108,000 OF 2020 QUALIFIED DISTRIBUTIONS AS BEING MADE OUT OF CORPUS AS REPORTED ON LINE 7 OF PART XII.PURSUANT TO INTERNAL REVENUE CODE SECTION 4942(H) AND TREASURY REGULATIONS SECTION 53.4942(A)-3(C)(2)(IV), THE TAXPAYER HEREBY ELECTS TO SATISFY THE REQUIREMENTS OF IRC SECTION 170(B)(1)(F)(II) TO TREAT AS CURRENT DISTRIBUTION OUT OF CORPUS AN ADDITIONAL $108,000 WHICH WAS PREVIOUSLY DISTRIBUTED INCOME IN 2020 AND NOT USED FOR ANY OTHER PURPOSE. THE TAXPAYER HEREBY ELECTS TO TREAT SUCH AMOUNT AS A DISTRIBUTION OUT OF CORPUS UNDER TREASURY REGULATIONS SECTION 53.4942(A)-3(D)(2). THE TAXPAYER IS ALLOWED TO MAKE SUCH ELECTIONS BECAUSE (1) SUCH AMOUNT WAS A QUALIFYING DISTRIBUTION BY THE PRIVATE FOUNDATION UNDER IRC SECTION 4942, (2) SUCH QUALIFYING DISTRIBUTION OCCURRED WITHIN THE PRECEDING FIVE YEARS, AND (3) SUCH QUALIFYING DISTRIBUTION WAS NOT LATER AVAILED OF FOR ANY OTHER PURPOSE. THIS AMOUNT IS INCLUDED ON PART XII, LINE 7 FOR A TOTAL OUT OF CORPUS ELECTION OF $108,000. THE TAXPAYER MADE CUMULATIVE QUALIFYING DISTRIBUTIONS OUT OF CORPUS IN THE AMOUNT OF $108,000 WHICH IS THE AMOUNT REPORTED ON PART XII LINE 7. THIS IS AN AMOUNT EQUAL TO 100% OF ALL CONTRIBUTIONS RECEIVED BY THE TAXPAYER DURING TAX YEAR 2021. THE TAXPAYER ALSO HAS NO UNDISTRIBUTED INCOME UNDER INTERNAL REVENUE CODE SECTION 4942(A). AS SUCH, THE TAXPAYER MEETS THE REQUIREMENTS OF INTERNAL REVENUE CODE SECTION 170(B)(1)(A)(VII), 170(B)(1)(F)(II), AND 4942(H) AS A FOUNDATION QUALIFYING FOR THE INCREASED CHARITABLE CONTRIBUTION LIMITS GENERALLY AFFORDED TO PUBLIC CHARITIES.