Mark Dewhirst, DVM, PhD
Duke University Medical Center

 Tom Hei, PhD
Columbia University Medical Center
Vice-Chair
 Kathryn Held, PhD
Massachusetts General Hospital

Bruce Kimler, PhD
University of Kansas Medical Center
Secretary-Treasurer 
William McLaughlin, MBA
Precision X-Ray

 Simon Powell, MD, PhD
Memorial Sloan Kettering
Cancer Center
Jacqueline Williams, PhD
University of Rochester
Medical Center
Chair

 
The Radiation Research Foundation (RRF) is a nonprofit, 501c3 foundation created in 2016 to support junior faculty engaged in radiation research.


The Basics
Section 501(c)(3) is the portion of the US Internal Revenue Code that allows for federal tax exemption of nonprofit organizations, specifically those that are considered public charities, private foundations or private operating foundations. It is regulated and administered by the US Department of Treasury through the Internal Revenue Service.


Qualifying Entities
Entities that can seek 501(c)(3) determination from the IRS include corporations, trusts, community chests, LLCs, and unincorporated associations. The overwhelming majority of 501(c)(3) organizations are nonprofit corporations.


Provisions Unique to 501(c)(3)
One of the most distinct provisions unique to Section 501(c)(3) organizations as compared with other tax exempt entities is the tax deductibility of donations. 26 U.S.C. § 170, provides a deduction, for federal income tax purposes, for some donors who make charitable contributions to most types of 501(c)(3) organizations. Other unique provisions tend to vary by state. Like federal law, most states allow for deductibility for state income tax purposes. Also, many states allow 501(c)(3) organizations to be exempt from sales tax on purchases, as well as exemption from property taxes. Special nonprofit, bulk rate postage discounts are available from the Post Office to qualifying organizations.


Types of 501(c)(3) Organizations
501(c)(3) organizations fall into one of three primary categories: public charities, private foundations, and private operating foundations.

A public charity is generally defined by the IRS as “not a private foundation”. It receives a substantial portion of its revenue from the general public or from government. In order to remain a public charity (and not a private foundation), a 501(c)(3) must obtain at least 1/3 of its donated revenue from a fairly broad base of public support. Public support can be from individuals, companies and/or other public charities. Donations to public charities can be tax deductible to the individual donor up to 50% of the donor’s income[2,3]. Corporate limits are generally 10%. In addition, public charities must maintain a governing body that is mostly made up of unrelated individuals. Public charities are what most people recognize as those organizations with active programs. Examples include churches, benevolence organizations, animal welfare agencies, educational organizations, etc.

A private foundation is often referred to as a non-operating foundation, as in it typically does not have active programs. Revenue may come from a relatively small number of donors, even single donors. Private foundations are usually thought of as nonprofits which support the work of public charities through grants, though that is not always the case. Donations to private foundations can be tax deductible to the individual donor up to 30% of the donor’s income. Governance of a private foundation can be much more closely held than in a public charity. A family foundation is an example of a private foundation.

The third category is the least common: private operating foundation. These organizations often maintain active programs similar to public charities, but may have attributes (such as close governance) similar to a foundation. As such, private operating foundations are often considered hybrids. Most of the earnings must go to the conduct of programs. Donation deductibility is similar to a public charity.


Restrictions on Activities
501(c)(3) organizations are highly regulated entities. Strict rules apply to both the activities and the governance of these organizations. No part of the activities or the net earnings can unfairly benefit any director, officer, or any private individual, and no officer or private individual can share in the distribution of any of the corporate assets in the event the organization shuts down. Further, lobbying, propaganda or other legislative activity must be kept relatively insubstantial. Intervention in political campaigns or the endorsement/anti-endorsement of candidates for public office is strictly prohibited.




  Radiation Research Foundation
For more information on the Radiation Research Foundation (RRF), contact us by: EMAIL or at (913) 588-4523.
www.radresfoundation.org