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The second method of satisfying the integral part test
is described by section 1.509(a)-4(i)(3)(iii), Income Tax
Regs., as follows:
(iii)(a) The supporting organization makes
payments of substantially all of its income to or
for the use of one or more publicly supported
organizations, and the amount of support received
by one or more of such publicly supported organ-
izations is sufficient to insure the attentive-
ness of such organizations to the operations of
the supporting organization. In addition, a
substantial amount of the total support of
the supporting organization must go to those
publicly supported organizations which meet the
attentiveness requirement of this subdivision
with respect to such supporting organization.
Except as provided in (b) of this subdivision,
the amount of support received by a publicly
supported organization must represent a
sufficient part of the organization's total
support so as to insure such attentiveness.
In applying the preceding sentence, if such
supporting organization makes payments to, or
for the use of, a particular department or
school of a university, hospital or church, the
total support of the department or school shall
be substituted for the total support of the
beneficiary organization.
(b) Even where the amount of support
received by a publicly supported beneficiary
organization does not represent a sufficient part
of the beneficiary organization's total support,
the amount of support received from a supporting
organization may be sufficient to meet the
requirements of this subdivision if it can be
demonstrated that in order to avoid the
interruption of the carrying on of a particular
function or activity, the beneficiary organiza-
tion will be sufficiently attentive to the
operations of the supporting organization.
This may be the case where either the support-
ing organization or the beneficiary organization
earmarks the support received from the support-
ing organization for a particular program or
activity, even if such program or activity is not
the beneficiary organization's primary program or
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