| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| Accounting fees | 77,618 | 1,832 | 0 | 75,786 |
| Description of Property | Date Acquired | Cost or Other Basis | Prior Years' Depreciation | Computation Method | Rate / Life (# of years) |
Current Year's Depreciation Expense | Net Investment Income | Adjusted Net Income | Cost of Goods Sold Not Included |
|---|---|---|---|---|---|---|---|---|---|
| 8301 E. Prentice Avenue | 2024-05-31 | 700,570 | SL | 39.000000000000 | 10,479 | 0 | 10,479 |
| Identifier | Return Reference | Explanation |
|---|---|---|
| Form 990-PF, Part II, Line 13 | During the tax year, the organization received a Schedule K-1 from a U.S. partnership that reported indirect ownership interests in one or more Passive Foreign Investment Companies (PFICs) and/or Controlled Foreign Corporations (CFCs).The partnership has represented that it made elections under IRC 1295 (Qualified Electing Fund) or 1296 (Mark-to-Market), as applicable, and that it has complied with the reporting requirements of IRC 1298(f) by filing Form 8621 for each PFIC held.Pursuant to Treas. Reg. 1.1298-1(b)(2)(ii), the organization as an indirect U.S. shareholderis not required to file Form 8621 with respect to these PFIC holdings. The income items reported on Schedule K-1 are considered passive investment income and are not subject to unrelated business income tax (UBIT).In addition, the partnership made an election under Treas. Reg. 1.1411-10(g) with respect to its PFIC/QEF and CFC investments. This election affects the computation of net investment income under IRC 1411 for individual or trust partners only and has no impact on the organization's Form 990 or 990-T reporting, as the organization is exempt from tax under IRC 501(c)(3)In addition, the partnership reported transfers of property to foreign corporations and has represented that it filed Form 926 in accordance with IRC 6038B. The organization was not a direct transferor and, under Treas. Reg. 1.6038B-1(b)(3), is not required to file Form 926 separately.All income reported from this investment represents passive investment activity not subject to unrelated business income tax (UBIT). | |
| Explanation re. potential self-dealing concern (Line 1a1) | Form 990-PF, Part VI-B, Line 1a1 | This following explanation provides a factual summary of the transaction structure to assist the IRS in evaluating the transaction under IRC 4941.The transaction concerned the sale of an S corporation in which The Ryan Foundation, a private foundation, was the principal seller, holding more than a 50% pro-rata ownership interest. The buyers qualified as disqualified persons under 4946.The initial proposal was structured as a merger; however, The Ryan Foundation declined to consent to the sale of its stock without first obtaining a qualified, independent appraisal to substantiate the proposed price, among other things. Although the company subsequently provided an appraisal, it did not conform to customary valuation principles under 4941. Instead, approximately 80% of the appraisal's weighting was based on the disqualified buyers' own determination of value.When the merger could not proceed, the buyers elected to purchase the company's assets rather than its stock. This alternative structure, the second proposed transaction was executed later in the same tax year, followed by the company's dissolution. As a result, the disqualified buyers acquired ownership and control of the assets and income previously held by the corporation, in which The Ryan Foundation was a majority shareholder, without the Foundation's consent, participation, or the benefit of a credible, independent valuation. In effect, the disqualified buyers sold the company to themselves at a price they unilaterally determined.The Foundation believes the facts described above may raise potential questions under 4941. Accordingly, this disclosure is being made voluntarily to enable the IRS to evaluate the transaction and determine the appropriate treatment, if any, under the self-dealing rules. |
| Name of Bond | End of Year Book Value | End of Year Fair Market Value |
|---|---|---|
| Charles Schwab fixed income | 862,824,459 | 862,824,459 |
| Name of Stock | End of Year Book Value | End of Year Fair Market Value |
|---|---|---|
| Charles Schwab equities | 562,288,012 | 562,288,012 |
| Category/ Item | Listed at Cost or FMV | Book Value | End of Year Fair Market Value |
|---|---|---|---|
| Guilford Capital Credit LP | FMV | 1,200,350 | 1,200,350 |
| Barings Capital Invst Corp | FMV | 1,019,028 | 1,019,028 |
| Palmer Square Opporunistic FD | FMV | 1,027,435 | 1,027,435 |
| Kayne Anderson BDC Inc | FMV | 2,683,884 | 2,683,884 |
| KA Credit Advisors Holding CO | FMV | 308,633 | 308,633 |
| Blackstone Real Estate Income | FMV | 5,280,548 | 5,280,548 |
| Starwood Real Estate Income | FMV | 2,303,203 | 2,303,203 |
| Orion Holdings-Mission related | FMV | 3,243,750 | 3,243,750 |
| Category / Item | Cost / Other Basis | Accumulated Depreciation | Book Value | End of Year Fair Market Value |
|---|---|---|---|---|
| 8301 E. Prentice Avenue | 700,570 | 10,479 | 690,091 |
| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| Legal fees | 1,903,295 | 0 | 0 | 0 |
| Description | Beginning of Year - Book Value | End of Year - Book Value | End of Year - Fair Market Value |
|---|---|---|---|
| Other deposit | 6,116 | 0 | 0 |
| Other asset | 151,542 | 0 | 0 |
| Prepaid expense | 0 | 9,998 | 9,998 |
| Description | Revenue and Expenses per Books | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| Dues and subscriptions | 29,335 | 0 | 0 | 29,335 |
| Office expenses | 25,148 | 0 | 0 | 25,148 |
| Information technology | 117,687 | 66,000 | 0 | 51,687 |
| Insurance | 922 | 0 | 0 | 922 |
| Penalties | 2,670 | 0 | 0 | 0 |
| Description | Revenue And Expenses Per Books | Net Investment Income | Adjusted Net Income |
|---|---|---|---|
| Other investment income - KA Credit Advisors | 5,736 | 0 | 0 |
| Other income | 1,200,000 | 0 |
| Description | Amount |
|---|---|
| Unrealized gain | 26,827,020 |
| Cash to Accrual Differences | 7,003,073 |
| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| Investment management fees | 940,826 | 940,826 | 0 | 0 |
| Consulting fees | 64,774 | 13,995 | 0 | 50,779 |
| Category | Amount | Net Investment Income | Adjusted Net Income | Disbursements for Charitable Purposes |
|---|---|---|---|---|
| State income taxes | 1,247,482 | 0 | 0 | 0 |
| Federal income taxes | 141,880 | 0 | 0 | 0 |