| Identifier | Return Reference | Explanation |
|---|---|---|
| Form 990-PF, Part VII, Section B Line1 a 2 | There is no interest being charged on the loans to or from the Foundation. | |
| Form 990-PF, Part VII, Section B Line2 b | Introduction: The Charis Foundation, Inc. (the "Foundation") respectfully requests abatement from the tax imposed under Internal Revenue Section 4942 for failure to distribute income. Pursuant to Section 4942(a)(2)(e), any failure for the Foundation to value the assets properly was due to reasonable cause and not willful neglect. Foundation Background: The Foundation was established in December 2015 to further charitable, religious, research, educational, and scientific purposes. Specifically, the Foundation seeks to provide housing, food, clothing, health care and education to orphans and other vulnerable children in developing countries. The Foundation also plans to provide grants for developing a sustainable business in order to encourage the orphans and other vulnerable children it helps to become self-sufficient. The Foundation is primarily funded through contributions and revenues earned from its investments. The Foundation is exempt from federal income tax as an organization described in Section 501(c)(3). The Foundation is classified as a private foundation within the meaning of Section 509, and, therefore, is subject to the provisions of Chapter 42 of the Code. Distributable Income Requirement: During the Foundation's 2017 tax year, the Foundation received a donation of a 50% ownership interest in The Charis Rescue Foundation, LLC, a Florida limited liability company that operates a number of hospices and home health entities. None of the tax professionals that were assisting the Foundation at the time advised the Foundation and its board of directors that this type of ownership interest required the Foundation to obtain a valuation of the investment's fair market value on an annual basis. The valuation of the Foundation's non-charitable assets is needed to complete Part X, the Foundation's Minimum Investment Return. As a result of its reliance on its tax professionals, the Foundation did not obtain this valuation and thus did not report the correct fair market value of this ownership interest. Prompt Correction of Valuation and Undistributed Income: The Foundation's failure to obtain a fair market valuation was identified during an outside professional review of the Foundation's financial information. As soon as this failure was identified, the Foundation immediately engaged a law firm and an accounting firm with extensive tax-exempt experience to correct the omissions from the earlier tax years. The Foundation worked quickly to hire a qualified valuation firm to perform valuations of the ownership interests for the respective tax periods to obtain the fair market value of the donated ownership interest investment for disclosure on the tax returns and for the calculation of the Foundation's Minimum Investment Return. Upon completion of the valuations, the Foundation worked as quickly as possible to gather the necessary information to file complete and accurate tax returns and take corrective action in meeting the required distribution requirements. This action on part of the Foundation reflects the due diligence and good faith effort it has exercised to work towards being in full compliance with all filing requirements. The Foundation acted prudently by quickly trying to satisfy the filing requirements and believes that its failure to obtain valuations and timely file was due to reasonable cause and not due to willful neglect. The Foundation has also instituted safeguards to ensure compliance in the future, including establishing policies and procedures. Request for Abatement: Based on the information above, the Foundation respectfully requests abatement from the tax imposed under Section 4942. |
| Category/ Item | Listed at Cost or FMV | Book Value | End of Year Fair Market Value |
|---|---|---|---|
| Investment in The Charis Rescue Foundation, LLC. | FMV | 1,000,000 | 1,000,000 |
| Item No. | 1 |
|---|---|
| Lender's Name | Loan Payable - Kevin Ruark |
| Lender's Title | Spouse of Board Member |
| Original Amount of Loan | 13885 |
| Balance Due | 15268 |
| Date of Note | 2016-12 |
| Maturity Date | |
| Repayment Terms | Available Upon Request |
| Interest Rate | 0.0 |
| Security Provided by Borrower | N/A |
| Purpose of Loan | Operations |
| Description of Lender Consideration | N/A |
| Consideration FMV | 15268 |
| Description | Amount |
|---|---|
| Unrealized loss on investments | 560,000 |
| Description | Revenue and Expenses per Books | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| Bank Charges & Fees | 77 |