| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| TAX AND ACCOUNTING | 7,091 | 0 | 0 | 7,091 |
| Identifier | Return Reference | Explanation |
|---|---|---|
| FORM 990-PF, PAGE 1, LINES 6A, 6B, 7,AND 11, AND FORM 8275, PART II | THE FOUNDATION SOLD ITS INTEREST (THE "PROPERTY") IN REAL ESTATE LOCATED AT 7 - 76TH STREET, NEW YORK, NY. THIS INTEREST WAS RECEIVED BY THE FOUNDATION AS A DONATION IN 2015. THE PROPERTY WAS USED AS THE FOUNDATION'S HEADQUARTERS AND FOR CONDUCTING BUSINESS ACTIVITIES RELATED TO ITS CHARITABLE PURPOSE. IN ORDER TO GENERATE SOME REVENUE, THE PROPERTY OCCASIONALLY WAS ALSO RENTED OUT TO MOVIE STUDIOS AND TELEVISION NETWORKS FOR USE AS A FILM OR TELEVISION SET. THE FOUNDATION PARTICIPATES IN THE PUBLICATION OF A QUARTERLY MAGAZINE, TABIZURU, THAT FEATURES INTERVIEWS WITH GLOBAL LEADERS IN DIVERSE FIELDS. THE FOUNDATION IS IN THE PROCESS OF PRODUCING A DOCUMENTARY FILM IN FURTHERANCE OF ITS CHARITABLE PURPOSE THAT WILL ADDRESS CAUSES CHAMPIONED BY THE YOUNG GENERATION ACROSS THE GLOBE. THE FOUNDATION PLANS TO GENERATE REVENUE BY DISTRIBUTING THE FILM THROUGH VARIOUS CHANNELS, INCLUDING SOCIAL MEDIA, YOUTUBE, AND OTHERS. THE REVENUES TO BE GENERATED FROM THIS EDUCATIONAL FILM PROJECT WILL BE REINVESTED IN ADDITIONAL FUTURE EDUCATIONAL PROJECTS. THE FOUNDATION BELIEVES THAT THE PROPERTY WAS NOT A CAPITAL ASSET. RATHER, IT WAS REAL PROPERTY USED IN ITS TRADE OR BUSINESS, EXCLUDED FROM THE DEFINITION OF "CAPITAL ASSET" BY IRC SECTION 1221(A)(2). THE BOOK GAIN ON THE SALE IS SHOWN ON FORM 990-PF PAGE 1, LINE 6A. IT IS NOT SHOWN AS "CAPITAL GAIN NET INCOME" ON LINE 7 AS THE FOUNDATION BELIEVES THAT IT IS NOT CAPITAL GAIN NET INCOME WITHIN THE MEANING OF IRC SEC. 4940(C)(1). SECTION 4940(C )(1) DOES NOT DEFINE THE TERM, BUT ITS DEFINITION CAN BE FOUND IN IRC SEC. 1222(9), WHICH PROVIDES:THE TERM "CAPITAL GAIN NET INCOME" MEANS THE EXCESS OF THE GAINS FROM SALES OR EXCHANGES OF CAPITAL ASSETS OVER THE LOSSES FROM SUCH SALES OR EXCHANGES. THE TERM "CAPITAL ASSET" IS DEFINED BY IRC SEC. 1221. SEC 1221(A)(2) SPECIFICALLY EXCLUDES REAL PROPERTY USED IN THE TRADE OR BUSINESS FROM THE DEFINITION OF "CAPITAL ASSET." THUS, THE FOUNDATION BELIEVES THAT THE PROPERTY IS NOT A "CAPITAL ASSET AND GAIN FROM THE SALE OF THE PROPERTY IS NOT INCLUDED WITHIN "CAPITAL GAIN NET INCOME."REVENUE RULING 98-56, 1998-2 C.B. 667, IMPLICITLY CONFIRMS THAT SECTION 1231 GAINS ARE NOT PART OF "CAPITAL GAIN NET INCOME". SEE IRC SECTION 32(I)(2)(D) (DISQUALIFIED INCOME INCLUDES "CAPITAL GAIN NET INCOME").THUS, ALTHOUGH THE BOOK GAIN IS SHOWN ON FORM 990-PF, PAGE 1, LINE 6A, THE TAXABLE GAIN IS NOT TREATED AS "CAPITAL GAIN NET INCOME AND INSTEAD SHOWN ON LINE 11, COLUMN (C) FOR THE PURPOSE OF THE SEC. 4940 EXCISE TAX ON NET INVESTMENT INCOME. THE TAXABLE GAIN IS DETERMINED BY TAKING INTO ACCOUNT THE GROSS SELLING PRICE, MINUS THE SELLING EXPENSES, DONOR'S COST BASIS, AND ALLOWED OR ALLOWABLE DEPRECATION DURING THE HOLDING PERIOD. |
| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| LEGAL | 13,150 | 0 | 0 | 13,150 |
| Item No. | 1 |
|---|---|
| Lender's Name | EASIER AND AFFILIATES |
| Lender's Title | |
| Relationship to Insider | |
| Original Amount of Loan | 25,841 |
| Balance Due | 25,841 |
| Date of Note | |
| Maturity Date | |
| Repayment Terms | ON DEMAND |
| Interest Rate | |
| Security Provided by Borrower | NONE |
| Purpose of Loan | OPERATIONS |
| Description of Lender Consideration | |
| Consideration FMV |
| Description | Revenue and Expenses per Books | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| ADMINISTRATIVE EXPENSES | 16,500 | 0 | 16,500 | 0 |
| Description | Revenue And Expenses Per Books | Net Investment Income | Adjusted Net Income |
|---|---|---|---|
| 20% INTEREST IN REAL ESTATE AT 7 EAST 76TH STREET, NEW YORK, NY - STMT 14 | 0 | 6,475,732 |
| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| CONSULTING | 225,000 | 0 | 0 | 225,000 |
| OTHER | 231,380 | 0 | 29,936 | 201,444 |