EFTA01298340.pdf

INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY
P. 0. BOX 2508
CINCINNATI, OR 45201
10 er Identification Number:
Date: al 012at
J EPSTEIN VIRGIN ISLANDS FOUNDATION
INC IDA
6100 RED HOOK QUARTER STE 6-3 Contact Tele hone /Amber'
ST THOMAS, VI 00802
Account ng er od Ending:
December 31
Addendum Applies:
No
Dear Applicant:
Based on information supplied, and assuming your operations will be as
stated in your application for recognition of exemption, we have determined you
are exempt from Federal income tax under section 501(a) of the Internal
Revenue Code as an organisation described in section 501(c)(3).
Ne have further determined that, an indicated in your application, you
are a private foundation within the meaning of section 509(a) of the Code. In
this letter we are not determining whether you are an operating foundation as
defined in section 4942(j)(3)•
If your sources of support, or your purposes, character, or method of
operation change, please let us know so we can consider the effect of the
Change on your exempt status and foundation status. In the case of an amend-
ment to your organisational document or bylaws, please send us a copy of the
amended document or bylaws. Also, you should inform us of all changes in your
name or address.
As of January 1, 1984, you are liable for taxes under the Federal
Insurance Contributions Act (social security taxes) on remuneration of 8100
or more you pay to each of your employees during a calendar year. You are
not liable for the tax imposed under the Federal Unemployment Tax Act (FIJIA).
However, since you are a private foundation, you ars subject to excise taxes
under chapter 42 of the Code. You also may be subject to other Federal excise
taxes. If you have any questions about excise, employment, or other Federal
taxes, please let us know.
Donors may deduct contributions to you as provided in section 170 of the
Code Bequests, legacies, devises, transfers, or gifts to you or for your use
are deductible for Federal estate and gift tax purposes if they meet the
applicable provisions of sections 2055, 2106, and 2522 of the Code.
Contribution deductions are allowable to donors only to the extent that
their contributions are gifts, with no consideration received. Ticket pur-
chases and similar payments in conjunction with fundraising events may not
necessarily qualify as deductible contributions, depending on the Circum-
Letter 1076 (DO/CG)
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stances. See Revenue Ruling 67-246, published in Cumulative Bulletin 1967-2,
on page 104, which sets forth guidelines regarding the deductibility, as chari-
table contributions, of payments made by taxpayers for admission to or other
participation in fundraising activities for charity.
You are required to file Form 990-PF, Return of Private Foundation or
Section 4947(a)(1) Trust Treated as a Private Foundation. Form 990-PF must be
filed by the 15th day of the fifth month after the end of your annual account-
ing period. A penalty of $20 a day is charged when a return is filed late,
unless there is reasonable cause for the delay. However, the maximum penalty
charged cannot exceed $10,000 or 5 percent of your gross receipts for the year,
whichever is lees. For organizations with gross receipts exceeding $1,000,000
in any year, the penalty is $100 per day per return, unless there is reasonable
cause for the delay. The maximum penalty for an organization with gross
receipts exceeding $1,000,000 shall not exceed 050,000. This penalty may also
be charged if a return is not complete, so please be sure your return is
complete before you file it.
You are not required to file Federal income tax returns unless you are
subject to the tax on unrelated business income under section 511 of the Code.
If you are subject to this tax, you must file an income tax return on Form
990-T, Exempt Organization Business Income Tax Return. In this letter we
are not determining whether any of your present or proposed activities are
unrelated trade or business as defined in section 513 of the Code.
You are required to make certain returns available for public inspection
for three years after the later of the due date of the return or the date the
return is filed. The returns required to be made available for public
inspection are Form 990-PP, Return of Private Foundation or Section 4947(a)(1)
Nonexempt Charitable Trust Treated as a Private Foundation, and Form 4720,
Return of Certain Excise Taxes on Charities and Other Persons Under Chapters 41
and 4.2 of the Internal Revenue Code. You are also required to make available
for public inspection your exemption application, any supporting documents, and
your exemption letter. Copies of these documents must be provided to any
individual upon Written or in person request without charge other than
reasonable fees for copying and postage. You may fulfill this requirement by
placing these documents on the Internet. Penalties may be imposed for failure
to comply with these requirements. Additional information is available in
Publication 557, Tax-Exempt Status for Your Organization, or you may call our
toll free number shown above.
You need an employer identification number even if you have no employees.
If an employer identification number was not entered on your application, a
member will be assigned to you and you will be advised of it. Please use that
number on all returns you file and in all correspondence with the Internal
Revenue Service.
• This determination is based on evidence that your funds are dedicated
to the purposes listed in section 501(0)(3) of the Code. To assure your
continued exemption, you should maintain records to show that funds are
expended only for those purposes. If you distribute funds to other
Letter 1076 (DO/CC)
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organizations, your records should show whether they are exempt under
section' 501(c)(3). /n cases where the recipient organization is not exempt
under section S01(c)(3), there should be evidence that the funds will remain
dedicated to the required purposes and that they will be used for those
purposes by the recipient.
If we have indicated in the heading of this letter that an addendum
applies, the addendum enclosed is an integral part of this letter.
Because this letter could help resolve any questions about your exempt
status and foundation status, you should keep it in your permanent records.
If you have any questions, please contact the person whose name and
telephone number are shown in the heading of this letter.
Sincerely yours,
Director. Exempt Organizations
Letter 1076 (DO/CO)
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