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beneficiary organization’s primary program or activity
so long as such program or activity is a substantial
one.
All pertinent factors are to be considered under the
foregoing subtest in order to determine whether the amount of
support received by the beneficiary organization is sufficient to
ensure attentiveness. Sec. 1.509(a)-4(i)(3)(iii)(d), Income Tax
Regs. Factors highlighted by the regulations include the number
of beneficiaries, the length and nature of the relationship
between the organizations, the purpose to which the funds are
put, and the imposition of a requirement that the supporting
organization furnish reports to the supported organization. Id.
As a general premise, the regulations provide that the greater
the amount involved as a percentage of the beneficiary
organization’s total support, the greater the likelihood that the
required degree of attentiveness will be present. Id. There is,
however, the caveat that “evidence of actual attentiveness by the
beneficiary organization is of almost equal importance.” Id.
C. Section 509(a)(3)(C)
Section 509(a)(3)(C) specifies the third basic requirement
for all charitable entities wishing to be classified as
supporting organizations. A supporting organization may not be
controlled directly or indirectly by disqualified persons,
including substantial contributors; their family members; and
corporations, partnerships, or trusts in which interests of more
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