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50 percent act of self-dealing additional tax adjusted gross income applies assets benefit board of directors booklet business activity business income tax by-laws capital gains charitable organizations combat community deterioration conservation objectives conservation organizations contract contributions corporation correction period discussion disqualified person educa educational material educational organization exempt from tax exempt purposes exempt under Section facts foundation manager funds grant imposed includes incorporators influencing legislation Internal Revenue Code Internal Revenue Service investment income issues lative legislative activity membership nizations obtain operating foundation orga organiza organization exempt organization's permissible activities private foundations prohibited public foundation status publicly supported qualified distributions received regulations rules social welfare organization specific substantial contributor tax deductibility tax law tax liability Tax Reform Act tax under Section tax-exempt organizations tax-exempt purposes tax-exempt status taxable termination tion tional unrelated business activities unrelated business income urging the public viduals voting