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"Supporting Organization"
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EFTA02104621
Dataset 10
2014-06-03
2p
632w
Subject:
Re: For Jeffrey:
supporting organization
roadmap
To:
Russo, Raphael M
To: Russo, Raphael M Cc: Ezrin . Gre ory From: Sent: Tue 6/3/2014 6:10:26 PM Subject: Re: For Jeffrey:
supporting organization
roadmap great. thanks On Jun 3, 2014, at 1:56 PM, "Russo, Raphael M" < wrote: My office number is and my cell phone is IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02104621.pdf
EFTA02104386
Dataset 10
2014-06-03
2p
492w
Subject:
Re: For Jeffrey:
supporting organization
roadmap
To:
Russo, Raphael
To: Russo, Raphael From: Sent: Tue 6/3/2014 4:53:48 PM Subject: Re: For Jeffrey:
supporting organization
roadmap Hello Raphael. Could you provide me with a phone number in case Jeffrey wants to call you after 5pm today? Sent from my iPhone On Jun 3, 2014, at 10:54 AM, "Russo, Raphael M" wrote: We took a look over the weekend at the
supporting organization
roadmap that you sent us and have the following observations: Most importantly, there…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02104386.pdf
EFTA01923942
Dataset 10
2014-06-03
3p
640w
Subject:
RE: For Jeffrey:
supporting organization
roadmap
From:
Larry Cohen
To:
Jeffrey EMeevacation@gmaitcomi
…58 PM Subject: RE: For Jeffrey:
supporting organization
roadmap Thanks. Who else do you have attending today? Lisa Johnson will join us from Foundation From: jeffrey E. [mailto:
[email protected]
] Sent: Tuesday, June 3, 2014 8:20 AM To: Larry Cohen Subject: Fwd: For Jeffrey:
supporting organization
roadmap ----- Forwarded messa e From: Lesley Groff Date: Tue, Jun 3, 2014 at 11:00 AM Subject: Fwd: For Jeffrey:
supporting organization
roadmap To: Jeffrey Epstein
[email protected]
> Sent from my…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01923942.pdf
EFTA01923614
Dataset 10
2014-06-03
2p
497w
Subject:
Fwd: For Jeffrey:
supporting organization
roadmap
From:
"Russo, Raphael M"
To:
inBeevacation©gmail.com]
To: inBeevacation©gmail.com] From: Sent: Tue 6/3/2014 3:00:30 PM Subject: Fwd: For Jeffrey:
supporting organization
roadmap Sent from my iPhonc Begin forwarded message: From: "Russo, Raphael M" Date: June 3, 2014, 10:54:53 AM EDT To: ' .- Cc: "Ezring, Gregory A" AMIS Subject: For Jeffrey:
supporting organization
roadmap We took a look over the weekend at the
supporting organization
roadmap that you sent us and have the following observations: Most importantly, there are a number of…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01923614.pdf
EFTA01104447
Dataset 9
2011-12-05
117p
44,458w
…Act of 2006 (the PPA), the Department of the Treasury has conducted a study on the organization and operation of supporting organizations and donor advised funds. Section 1226(b) of the PPA directs the Secretary of the Treasury to submit a report on the
supporting organization
and donor advised fund study to Congress. Enclosed is our report on Supporting Organizations and Donor Advised Funds. An identical letter is addressed to Senator Hatch. Sincerely, Emily S. McMahon Acting Assistant Secretary (Tax…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104447.pdf
EFTA00314876
Dataset 9
15p
4,267w
…and organizational structure • The SO will have its own board of directors & makes its own decisions about investments, spending policies, and grantmaking • SO board composition o A majority of the
supporting organization
's board must be appointed or elected by the sponsoring public organization. Members of the SO's board do not have to be actually comprised of the sponsoring public organization's board, but may be their designees, induding officers of the public charity who are not board members…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00314876.pdf
EFTA00598168
Dataset 9
2007-01-01
4p
1,523w
…but that will be "taxable distributions" unless expenditure responsibility is followed include: ■ an organization that is not described in section 170(b)(1)(A) — notably non-charities and private non-operating foundations ■ a type III
supporting organization
that is not "functionally integrated" ■ a
supporting organization
(even a "functionally integrated" type III) if the organization that is being supported is controlled by either the donor or an advisor appointed by the donor What is a donor-advised fund…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598168.pdf
EFTA00869765
Dataset 9
2014-08-29
6p
1,375w
Subject:
Re:
From:
"Jeffrey E." <jeevacationggmail.eom>
To:
Larry Cohen
…o This new organization will sponsor donor-advised funds into which you can contribute. It will also serve as the parent of a
supporting organization
into which you can contribute. o Whether a donor-advised fund or a
supporting organization
is the right vehicle for you will depend on the assets you want to contribute and the amount of ongoing influence you would like to have, but in both cases you would be entitled to the more favorable charitable contribution…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00869765.pdf
EFTA00869771
Dataset 9
2014-08-29
6p
1,394w
Subject:
Re:
From:
"Jeffrey E." <jeevacationggmail.com>
To:
Larry Cohen >
…o This new organization will sponsor donor-advised funds into which you can contribute. It will also serve as the parent of a
supporting organization
into which you can contribute. o Whether a donor-advised fund or a
supporting organization
is the right vehicle for you will depend on the assets you want to contribute and the amount of ongoing influence you would like to have, but in both cases you would be entitled to the more favorable charitable contribution…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00869771.pdf
EFTA01104413
Dataset 9
2006-02-07
13p
5,131w
Indiana Law Review Volume 39 2006 Number 2 ARTICLES SUPPORTING THE
SUPPORTING ORGANIZATION
: THE POTENTIAL AND EXPLOITATION OF 509(A)(3) CHARITIES ALYSSA A. DIRusso' "One of the serious obstacles to the improvement of our race is indiscriminate charity." Andrew Carnegie' SUMMARY Supporting organizations, a type of charity defined in section 509(a)(3) of the Internal Revenue Code, have vast potential for philanthropic impact but perhaps equally vast potential for abuse. Donors who establish supporting organizations may retain inappropriate…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104413.pdf
EFTA02104659
Dataset 10
2014-06-03
1p
166w
To:
Russo, Raphael M
To: Russo, Raphael M Cc: Eznng, Gregory Al From: Sent Tue 6/3/2014 6:15:47 PM Subject Re: For Jeffrey:
supporting organization
roadmap Raphael, it is possible Jeffrey may wish to conference you in to his meeting today anytime between 6:30-8:30pm EST...if so , the dial in details are below...we will be in touch Toll-free dial-in number (U.S. and Canada): In rn inl i 1-in number: Conference code: Leader PIN…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02104659.pdf
EFTA01104426
Dataset 9
2006-07-26
21p
7,866w
…respectively, to report their activities. However, What GAO Recommends donor-advised fund data are limited because organizations that maintain the funds are not required to separately report fUnd data from other financial GAO suggests that Congress data on Form 990. Although some
supporting organization
characteristics consider (1) directing IRS to collect Form 990 data for, and provide can be determined from Form 990 data, other characteristics, such as the guidance on calculating payout rate at which payments are made to…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104426.pdf
EFTA00674730
Dataset 9
2p
709w
…organization to • IRS Letter of Determination* Yes make an expenditure or fr. • Written opinion of counsel prevent a supported • Written representation from grantee organization from making an combined with sponsoring expenditure. • Some IRS letters of determination organization review of supporting will include a determination of
supporting organization
Type. organization's governing documents and written representations from K However. most letters will not. Another method of determination each supported organization No will be required if the IRS letter of ♦ K …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00674730.pdf
EFTA00607663
Dataset 9
2p
709w
…organization to • IRS Letter of Determination* Yes make an expenditure or fr. • Written opinion of counsel prevent a supported • Written representation from grantee organization from making an combined with sponsoring expenditure. • Some IRS letters of determination organization review of supporting will include a determination of
supporting organization
Type. organization's governing documents and written representations from K However. most letters will not. Another method of determination each supported organization No will be required if the IRS letter of ♦ K …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607663.pdf
EFTA00598203
Dataset 9
2011-07-20
8p
3,395w
…AM EFTA00598208 GiftLaw Pro http://www.gcfccc.orglgi0law/gtawpro_aaic.jsp?NhbID=G12003-0474... An organization is described in this paragraph if such organization is-- (A) a type III
supporting organization
(other than a functionally integrated type III
supporting organization
), or (B) an organization which meets the requirements of subparagraphs (A) and (C) of section 509(a)(3) and which is supervised or controlled in connection with one or more organizations described in paragraph (1) or (2) of section 509(a)…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598203.pdf
EFTA01301134
Dataset 10
2019-09-11
30p
5,076w
…if good investments. may be retained if the aggregate public chanty asset allocation is prudently diversified. although DAFsare suEllett to excess business holdings rules • A majority of the public sponsonng organizations board must be independent • A majority of directors of the
supporting organization
must be appointed or elected by the sponsoringpublic organization. Members of the
supporting organization
's board do not have to be actually compnsed of the sponsonng public organizations board, but may be their designees, including officers of…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01301134.pdf
EFTA01301114
Dataset 10
2011-08-31
15p
2,359w
…Maximizes U.S. tax deductibility • Structure in a tax neutral jurisdiction will provide maximum flexibility for appropriate donors • Accommodates donations from private foundations • Country-specific entity options to meet donors' tax and • Avoids private foundation constraints regulatory considerations - 5% annual payout • Facilitates cross border philanthropic giving and 2% excise tax collaborative partnerships - Restrictive self dealing rules • Charitable foundation permits donor anonymity Donor Advised Fund option preserves anonymity
Supporting organization
allows for donor board positions Note: J.P. Morgan Chase will…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01301114.pdf
EFTA02517541
Dataset 11
2014-08-29
6p
1,392w
Subject:
Re:
From:
jeffrey E. <
[email protected]
>
To:
Larry Cohen
…This new organization will sponsor donor-advised fund= into which you can contribute. It will also serve as the parent of =
supporting organization
into which you can contribute.</=> o Whether a donor-advised fund or a supporting organiza=ion is the right vehicle for you will depend on the assets you want to con=ribute and the amount of ongoing influence you would like to have, but in both cases you would be entitled to the more favorabl= charitable…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02517541.pdf
EFTA02693048
Dataset 11
2011-08-31
15p
2,125w
…Maximizes U.S. tax deductibility • Structure in a tax neutral jurisdiction will provide maximum flexibility for appropriate donors • Accommodates donations from private foundations • Country-specific entity options to meet donors' tax and • Avoids private foundation constraints regulatory considerations 5% annual payout • Facilitates cross border philanthropic giving and 2% excise tax collaborative partnerships Restrictive self dealing rules • Charitable foundation permits donor anonymity • Donor Advised Fund option preserves anonymity •
Supporting organization
allows for donor board positions Note: J.P. Morgan Chase will…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02693048.pdf
EFTA02517554
Dataset 11
2014-08-29
6p
1,408w
Subject:
Re:
From:
jeffrey E. <
[email protected]
>
To:
Larry Cohen
…This new organization will sponsor donor-advised fund= into which you can contribute. It will also serve as the parent of =
supporting organization
into which you can contribute.</=> o Whether a donor-advised fund or a supporting organiza=ion is the right vehicle for you will depend on the assets you want to con=ribute and the amount of ongoing influence you would like to have, but in both cases you would be entitled to the more favorabl= charitable…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02517554.pdf
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