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(b) One or more members of the governing bodies of
the publicly supported organizations are also officers,
directors or trustees of, or hold other important
offices in, the supporting organizations; or
(c) The officers, directors or trustees of the
supporting organization maintain a close and continuous
working relationship with the officers, directors or
trustees of the publicly supported organizations; and
(d) By reason of (a), (b), or (c) of this
subdivision, the officers, directors or trustees of the
publicly supported organizations have a significant
voice in the investment policies of the supporting
organization, the timing of grants, the manner of
making them, and the selection of recipients of such
supporting organization, and in otherwise directing the
use of the income or assets of such supporting
organization. [Sec. 1.509(a)-4(i)(2)(ii), Income Tax
Regs.]
The integral part test seeks to ensure that the supporting
organization “maintains a significant involvement in the
operations of one or more publicly supported organizations and
such publicly supported organizations are in turn dependent upon
the supporting organization for the type of support which it
provides.” Sec. 1.509(a)-4(i)(3)(i), Income Tax Regs. Two
alternative sets of criteria exist under the regulations for
satisfying this test. Id. The first alternative (sometimes
referred to for convenience by the parties (with different
punctuation) and herein as the “but-for subtest”) is set forth in
section 1.509(a)-4(i)(3)(ii), Income Tax Regs.:
The activities engaged in for or on behalf of the
publicly supported organizations are activities to
perform the functions of, or to carry out the purposes
of, such organizations, and, but for the involvement of
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