Attach to Form 990 or Form 990-EZ.
Go to
www.irs.gov/Form990 for instructions and the latest information.
| (i) Name of supported organization | (ii) EIN | (iii) Type of organization (described on lines 1- 10 above (see instructions)) | (iv) Is the organization listed in your governing document? | (v) Amount of monetary support (see instructions) | (vi) Amount of other support (see instructions) | |
|---|---|---|---|---|---|---|
| Yes | No | |||||
|
Total |
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Calendar year (or fiscal year beginning in) ![]() |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") .. | 5,788,478 | 5,084,533 | 5,542,951 | 6,457,941 | 4,220,130 | 27,094,033 |
| 2 | Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.... | ||||||
| 3 | The value of services or facilities furnished by a governmental unit to the organization without charge.. | ||||||
| 4 | Total. Add lines 1 through 3 | 5,788,478 | 5,084,533 | 5,542,951 | 6,457,941 | 4,220,130 | 27,094,033 |
| 5 | The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included on line 1 that exceeds 2% of the amount shown on line 11, column (f).. | 23,928,106 | |||||
| 6 | Public support. Subtract line 5 from line 4. | 3,165,927 | |||||
Calendar year
(or fiscal year beginning in) ![]() |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 7 | Amounts from line 4.. | 5,788,478 | 5,084,533 | 5,542,951 | 6,457,941 | 4,220,130 | 27,094,033 |
| 8 | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources... | ||||||
| 9 | Net income from unrelated business activities, whether or not the business is regularly carried on.. | ||||||
| 10 | Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.).. | 660 | 660 | ||||
| 11 | Total support. Add lines 7 through 10 | 27,094,693 | |||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") . | ||||||
| 2 | Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose | ||||||
| 3 | Gross receipts from activities that are not an unrelated trade or business under section 513 ..... | ||||||
| 4 | Tax revenues levied for the organization's benefit and either paid to or expended on its behalf... | ||||||
| 5 | The value of services or facilities furnished by a governmental unit to the organization without charge | ||||||
| 6 | Total. Add lines 1 through 5 | ||||||
| 7a | Amounts included on lines 1, 2, and 3 received from disqualified persons | ||||||
| b | Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year. | ||||||
| c | Add lines 7a and 7b.. | ||||||
| 8 | Public support. (Subtract line 7c from line 6.) | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 9 | Amounts from line 6... | ||||||
| 10a | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources.. | ||||||
| b | Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975. | ||||||
| c | Add lines 10a and 10b. | ||||||
| 11 | Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on. | ||||||
| 12 | Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.) .. | ||||||
| 13 | Total support. (Add lines 9, 10c, 11, and 12.).. | ||||||
| Section A - Adjusted Net Income | (A) Prior Year |
(B) Current Year (optional) |
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| 1 | Net short-term capital gain | 1 | ||||
| 2 | Recoveries of prior-year distributions | 2 | ||||
| 3 | Other gross income (see instructions) | 3 | ||||
| 4 | Add lines 1 through 3 | 4 | ||||
| 5 | Depreciation and depletion | 5 | ||||
| 6 | Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions) | 6 | ||||
| 7 | Other expenses (see instructions) | 7 | ||||
| 8 | Adjusted Net Income (subtract lines 5, 6 and 7 from line 4) | 8 | ||||
| Section B - Minimum Asset Amount | (A) Prior Year |
(B) Current Year (optional) |
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| 1 | Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year): | 1 | ||||
| a | Average monthly value of securities | 1a | ||||
| b | Average monthly cash balances | 1b | ||||
| c | Fair market value of other non-exempt-use assets | 1c | ||||
| d | Total (add lines 1a, 1b, and 1c) | 1d | ||||
| e |
Discount claimed for blockage or other factors (explain in detail in Part VI): |
|||||
| 2 | Acquisition indebtedness applicable to non-exempt use assets | 2 | ||||
| 3 | Subtract line 2 from line 1d | 3 | ||||
| 4 | Cash deemed held for exempt use. Enter 0.015 of line 3 (for greater amount, see instructions). | 4 | ||||
| 5 | Net value of non-exempt-use assets (subtract line 4 from line 3) | 5 | ||||
| 6 | Multiply line 5 by 0.035 | 6 | ||||
| 7 | Recoveries of prior-year distributions | 7 | ||||
| 8 | Minimum Asset Amount (add line 7 to line 6) | 8 | ||||
| Section C - Distributable Amount | Current Year | |||||
| 1 | Adjusted net income for prior year (from Section A, line 8, Column A) | 1 | ||||
| 2 | Enter 85% of line 1 | 2 | ||||
| 3 | Minimum asset amount for prior year (from Section B, line 8, Column A) | 3 | ||||
| 4 | Enter greater of line 2 or line 3 | 4 | ||||
| 5 | Income tax imposed in prior year | 5 | ||||
| 6 | Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions) | 6 | ||||
| Section D - Distributions | Current Year | |
|---|---|---|
| 1 Amounts paid to supported organizations to accomplish exempt purposes | 1 | |
|
2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
2 | |
| 3 Administrative expenses paid to accomplish exempt purposes of supported organizations | 3 | |
| 4 Amounts paid to acquire exempt-use assets | 4 | |
| 5 Qualified set-aside amounts (prior IRS approval required - provide details in Part VI) | 5 | |
| 6 Other distributions (describe in Part VI). See instructions | 6 | |
| 7Total annual distributions. Add lines 1 through 6. | 7 | |
|
8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
8 | |
| 9 Distributable amount for 2020 from Section C, line 6 | 9 | |
| 10 Line 8 amount divided by Line 9 amount | 10 | |
| Section E - Distribution Allocations (see instructions) |
(i) Excess Distributions |
(ii) Underdistributions Pre-2020 |
(iii) Distributable Amount for 2020 |
|
|---|---|---|---|---|
| 1 Distributable amount for 2020 from Section C, line 6 | ||||
|
2
Underdistributions, if any, for years prior to 2019 (reasonable cause required-- explain in Part VI). See instructions. |
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| 3 Excess distributions carryover, if any, to 2020: | ||||
| a From 2015....... | ||||
| b From 2016....... | ||||
| c From 2017....... | ||||
| d From 2018....... | ||||
| e From 2019....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2020 distributable amount | ||||
|
i
Carryover from 2015 not applied (see instructions) |
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| j Remainder. Subtract lines 3g, 3h, and 3i from line 3f. | ||||
| 4Distributions for 2020 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2020 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from line 4. | ||||
|
5
Remaining underdistributions for years prior to 2020, if any. Subtract lines 3g and 4a from line 2. If the amount is greater than zero, explain in Part VI. See instructions. |
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|
6
Remaining underdistributions for 2020. Subtract lines 3h and 4b from line 1. If the amount is greater than zero, explain in Part VI. See instructions. |
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|
7 Excess distributions carryover to 2021. Add lines 3j and 4c. |
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| 8 Breakdown of line 7: | ||||
| a Excess from 2016..... | ||||
| b Excess from 2017..... | ||||
| c Excess from 2018..... | ||||
| d Excess from 2019..... | ||||
| e Excess from 2020..... | ||||
| Facts And Circumstances Test |
|---|
| ATHE ORGANIZATION'S PUBLIC SUPPORT IS 11.68%, WHICH IS ABOVE THE 10% THRESHOLD.THE ORGANIZATION IS ORGANIZED AND OPERATED TO ATTRACT NEW AND ADDITIONAL PUBLIC AND GOVERNMENTAL SUPPORT ON A CONTINUOUS BASIS. THE ORGANIZATION CONTINUOUSLY SOLICITS SMALL-DOLLAR CONTRIBUTIONS ONLINE THROUGH ITS WEBSITE, GOVERNMENT GRANTS, NON-PROFIT GRANTS, CORPORATE DONATIONS AND INDIVIDUAL DONATIONS, ALWAYS SEEKING TO EXPAND ITS DONOR BASE.SINCE ITS FOUNDING IN 2008, THE ORGANIZATION'S DONORS HAVE INCLUDED INDIVIDUALS (BOTH MAJOR DONORS AND GRASSROOTS DONORS), CORPORATIONS, PRIVATE FOUNDATIONS, AND OTHER TAX-EXEMPT ORGANIZATIONS FROM ACROSS THE UNITED STATES. THE ORGANIZATION'S PROGRAMS AND ACTIVITIES, WHICH FOCUS ON EDUCATING THE PUBLIC ABOUT IRAN-RELATED POLICY ISSUES, BROADLY APPEAL TO THE PUBLIC BOTH DOMESTICALLY AND INTERNATIONALLY. THE ORGANIZATION'S ONLINE RESOURCES DESCRIBED BELOW PROVIDED A VALUABLE PUBLIC SERVICE.THE ORGANIZATION IS GOVERNED BY A THREE-MEMBER BOARD OF DIRECTORS, TWO OF WHOM HAVE SPECIAL KNOWLEDGE AND EXPERTISE IN THE FIELD OF INTERNATIONAL RELATIONS. THE ORGANIZATION ALSO MAINTAINS A 30-PERSON ADVISORY BOARD CONSISTING OF FORMER PUBLIC OFFICIALS, FORMER DIPLOMATS, ACADEMICS, AND OTHER THOUGHT LEADERS FROM THE UNITED STATES AND ACROSS THE GLOBE.THE ORGANIZATION CONDUCTS A VARIETY OF PROGRAMS AND ACTIVITIES TO EDUCATE THE PUBLIC ABOUT THE NATURE OF THE IRANIAN REGIME, THE THREATS IRAN POSES TO GLOBAL SECURITY, AND THE IMPACT OF IRAN-RELATED PUBLIC POLICIES. FOR EXAMPLE, THE ORGANIZATION'S RESEARCH ON IRANIAN BUSINESS ACTIVITIES (THE IRAN BUSINESS REGISTRY) IS AVAILABLE TO THE PUBLIC ON THE ORGANIZATION'S WEBSITE. THIS DATABASE IS WIDELY USED BY INDIVIDUALS AND BUSINESSES TO MAKE INFORMED PURCHASING, INVESTMENT, AND DIVESTMENT DECISIONS, AND IS ALSO A RESOURCE FOR THE MEDIA, ACADEMICS, RESEARCHERS, AND POLICYMAKERS.THE ORGANIZATION PERIODICALLY SPONSORS EDUCATIONAL EVENTS, SUCH AS PANEL DISCUSSIONS AND CONFERENCES, THAT ARE OPEN TO THE PUBLIC AND WIDELY ATTENDED, PROVIDING A FORUM FOR PUBLIC OFFICIALS, ACADEMICS, AND OTHER THOUGHT LEADERS TO DISCUSS PUBLIC POLICY ISSUES. THE ORGANIZATION OFTEN POSTS VIDEOS OF SUCH EVENTS ON ITS WEBSITE, AND SOMETIMES THE EVENTS ARE CARRIED ON C-SPAN OR OTHER MEDIA CHANNELS. THE ORGANIZATION ALSO DISTRIBUTES A DAILY EMAIL NEWSLETTER, EYE ON IRAN, COMPILING NEWS CLIPPINGS ON DEVELOPMENTS IN IRAN. MEMBERS OF THE PUBLIC MAY SUBSCRIBE TO THIS FREE NEWSLETTER, AND ARCHIVED COPIES OF THE NEWSLETTER ARE PUBLICLY AVAILABLE ON THE ORGANIZATION'S WEBSITE. THE ORGANIZATION ATTRACTS MANY VOLUNTEERS EACH YEAR, INCLUDING THE ADVISORY BOARD MEMBERS AND VOLUNTEERS SUPPORTING VARIOUS EVENTS. |
| Return Reference | Explanation |
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Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
|---|---|
| FORM 990, PART VI, SECTION B, LINE 11B | THE ORGANIZATION HAS ITS FORM 990 PREPARED BY AN OUTSIDE ACCOUNTING FIRM. IT IS THEN REVIEWED BY THE EXECUTIVE DIRECTOR AND A COMPLETE COPY IS PROVIDED TO ALL MEMBERS OF THE ORGANIZATION'S GOVERNING BODY FOR THEIR REVIEW PRIOR TO FILING. |
| FORM 990, PART VI, SECTION B, LINE 12C | THE ORGANIZATION'S CONFLICT OF INTEREST POLICY IS APPLICABLE TO ALL DIRECTORS, OFFICERS AND KEY EMPLOYEES. IN CONNECTION WITH ANY ACTUAL OR POSSIBLE CONFLICT OF INTEREST, AN INTERESTED PERSON MUST DISCLOSE ON AN ONGOING BASIS THE EXISTENCE OF ANY POTENTIAL CONFLICT AND BE GIVEN THE OPPORTUNITY TO DISCLOSE ALL MATERIAL FACTS TO THE DIRECTORS AND MEMBERS OF COMMITTEES WITH BOARD OF DIRECTORS DELEGATED POWERS CONSIDERING THE PROPOSED TRANSACTION OR ARRANGEMENT. AFTER DISCLOSURE OF THE FINANCIAL INTEREST AND ALL MATERIAL FACTS, AND AFTER ANY DISCUSSION WITH THE INTERESTED PERSON, HE/SHE SHALL LEAVE THE BOARD OF DIRECTORS OR COMMITTEE WITH BOARD OF DIRECTORS DELEGATED POWERS MEETING WHILE THE DETERMINATION OF A CONFLICT OF INTEREST IS DISCUSSED AND VOTED UPON. THE REMAINING BOARD OR COMMITTEE MEMBERS SHALL DECIDE IF A CONFLICT OF INTEREST EXISTS. AFTER EXERCISING DUE DILIGENCE, THE BOARD OF DIRECTORS OR COMMITTEE WITH BOARD OF DIRECTORS DELEGATED POWERS SHALL DETERMINE WHETHER THE CORPORATION CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. IF A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE BOARD OF DIRECTORS OR COMMITTEE WITH BOARD OF DIRECTORS DELEGATED POWERS SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED DIRECTORS WHETHER THE TRANSACTION OR ARRANGEMENT IS IN THE CORPORATION'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE TRANSACTION OR ARRANGEMENT. EACH DIRECTOR, PRINCIPAL OFFICER AND MEMBER OF A COMMITTEE WITH BOARD OF DIRECTORS DELEGATED POWERS SHALL ANNUALLY SIGN A STATEMENT WHICH AFFIRMS SUCH PERSON HAS RECEIVED A COPY OF THE CONFLICT OF INTEREST POLICY, HAS READ AND UNDERSTANDS THE POLICY AND HAS AGREED TO COMPLY WITH THE POLICY. ALL DECISIONS AND DELIBERATION ARE DOCUMENTED IN THE MINUTES OF THE BOARD. |
| FORM 990, PART VI, SECTION B, LINE 15 | THIS COMPENSATION REVIEW POLICY APPLIES TO THE ORGANIZATION'S CHIEF EXECUTIVE, OFFICERS AND KEY EMPLOYEES. THE COMPENSATION OF THE CHIEF EXECUTIVE AND EACH OFFICER, KEY EMPLOYEE OR DISQUALIFIED PERSON WAS REVIEWED AND APPROVED BY THE BOARD OF DIRECTORS OR COMPENSATION COMMITTEE OF THE CORPORATION, PROVIDED THAT DIRECTORS OR OTHER PERSONS WITH CONFLICTS OF INTEREST WITH RESPECT TO THE COMPENSATION ARRANGEMENT AT ISSUE SHALL NOT BE INVOLVED IN THIS REVIEW AND APPROVAL. THE COMPENSATION OF THE CHIEF EXECUTIVE AND EACH OFFICER, KEY EMPLOYEE OR DISQUALIFIED PERSON WAS REVIEWED AND APPROVED USING DATA AS TO COMPARABLE COMPENSATION FOR SIMILARLY QUALIFIED PERSONS IN FUNCTIONALLY COMPARABLE POSITIONS AT SIMILARLY SITUATED ENTITIES. THERE IS CONTEMPORANEOUS DOCUMENTATION AND RECORDKEEPING WITH RESPECT TO THE DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENT. THE BOARD OF DIRECTORS OR COMPENSATION COMMITTEE EVALUATING SUCH COMPENSATION ARRANGEMENT MAY, BUT SHALL NOT BE REQUIRED, TO USE THE "REBUTTABLE PRESUMPTION CHECKLIST OR OTHER TOOLS SET FORTH IN THE INTRODUCTION TO I.R.C. 4958. THIS PROCESS LAST OCCURED IN 2020. |
| FORM 990, PART VI, SECTION C, LINE 19 | THE GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS ARE AVAILABLE ON THIRD PARTY WEBSITES (SUCH AS GUIDESTAR.COM) OR UPON REQUEST. |
| FORM 990, PART VII-A: | COMPENSATION REPORTED TO ROBERT BENTON ON PART VII, COLUMN (D) WAS FOR LEGAL SERVICES PROVIDED AND NOT FOR SERVICES IN HIS CAPACITY AS SECRETARY OF THE ORGANIZATION. |
| FORM 990, PART IX, LINE 11G | CONSULTING AND OUTSIDE SERVICES: PROGRAM SERVICE EXPENSES 1,500,259. MANAGEMENT AND GENERAL EXPENSES 339. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 1,500,598. PAYROLL SERVICE FEES: PROGRAM SERVICE EXPENSES 1,699. MANAGEMENT AND GENERAL EXPENSES 3,449. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 5,148. STRATEGIC CONSULTANTS: PROGRAM SERVICE EXPENSES 347,000. MANAGEMENT AND GENERAL EXPENSES 0. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 347,000. |
| FORM 990, PART XI, LINE 9: | WRITE OFF OF UNCOLLECTIBLE GRANT -240,000. |
| FORM 990, PART XII, LINE 2C: | ACANI HAS A FINANCE COMMITTEE THAT IS RESPONSIBLE FOR THE OVERSIGHT OF THE AUDIT AND SELECTION OF THE INDEPENDENT AUDITOR. THE PROCESS HAS NOT CHANGED FROM PRIOR YEAR. |
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| Software Version: |