The EDTC Incubator

The EDTC Incubator
The Entrepreneurial Development Training
Center of the Leon H. Sullivan Charitable Trust
for Transformative
Social Impact ®
Proverbs 11:14; 15:22; 16:9
Acts 20:35 | Galatians 6:9 | 1 Corinthians 15:58
Luke 14:28 | Mark 10:42-45
Habakkuk 2:2
“Helping Individuals, Organizations & Communities
Achieve Their Full Potential”
Copyright © 2003-2018 The Advocacy Foundation, Inc. All Rights Reserved

Walk by Faith; Serve with Abandon
Expect to Win!
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The Advocacy Foundation, Inc.
Helping Individuals, Organizations & Communities
Achieve Their Full Potential
Since its founding in 2003, The Advocacy Foundation has become recognized as an effective
provider of support to those who receive our services, having real impact within the communities
we serve. We are currently engaged in community and faith-based collaborative initiatives,
having the overall objective of eradicating all forms of youth violence and correcting injustices
everywhere. In carrying-out these initiatives, we have adopted the evidence-based strategic
framework developed and implemented by the Office of Juvenile Justice & Delinquency
Prevention (OJJDP).
The stated objectives are:
1. Community Mobilization;
2. Social Intervention;
3. Provision of Opportunities;
4. Organizational Change and Development;
5. Suppression [of illegal activities].
Moreover, it is our most fundamental belief that in order to be effective, prevention and
intervention strategies must be Community Specific, Culturally Relevant, Evidence-Based, and
Collaborative. The Violence Prevention and Intervention programming we employ in
implementing this community-enhancing framework include the programs further described
throughout our publications, programs and special projects both domestically and
internationally.
www.TheAdvocacy.Foundation
ISBN: ......... ../2017
......... Printed in the USA
Advocacy Foundation Publishers
Philadelphia, PA
(878) 222-0450 | Voice | Data | SMS
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Dedication
______
Every publication in our many series’ is dedicated to everyone, absolutely everyone, who by
virtue of their calling and by Divine inspiration, direction and guidance, is on the battlefield dayafter-day
striving to follow God’s will and purpose for their lives. And this is with particular affinity
for those Spiritual warriors who are being transformed into excellence through daily academic,
professional, familial, and other challenges.
We pray that you will bear in mind:
Matthew 19:26 (NLT)
Jesus looked at them intently and said, “Humanly speaking, it is impossible.
But with God everything is possible.” (Emphasis added)
To all of us who daily look past our circumstances, and naysayers, to what the Lord says we will
accomplish:
Blessings!!
- The Advocacy Foundation, Inc.
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The Transformative Justice Project
Eradicating Juvenile Delinquency Requires a Multi-Disciplinary Approach
The way we accomplish all this is a follows:
The Juvenile Justice system is incredibly
overloaded, and Solutions-Based programs are
woefully underfunded. Our precious children,
therefore, particularly young people of color, often
get the “swift” version of justice whenever they
come into contact with the law.
Decisions to build prison facilities are often based
on elementary school test results, and our country
incarcerates more of its young than any other
nation on earth. So we at The Foundation labor to
pull our young people out of the “school to prison”
pipeline, and we then coordinate the efforts of the
legal, psychological, governmental and
educational professionals needed to bring an end
to delinquency.
We also educate families, police, local businesses,
elected officials, clergy, and schools and other
stakeholders about transforming whole communities,
and we labor to change their thinking about the
causes of delinquency with the goal of helping them
embrace the idea of restoration for the young people
in our care who demonstrate repentance for their
mistakes.
1. We vigorously advocate for charges reductions, wherever possible, in the
adjudicatory (court) process, with the ultimate goal of expungement or pardon, in
order to maximize the chances for our clients to graduate high school and
progress into college, military service or the workforce without the stigma of a
criminal record;
2. We then enroll each young person into an Evidence-Based, Data-Driven
Restorative Justice program designed to facilitate their rehabilitation and
subsequent reintegration back into the community;
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3. While those projects are operating, we conduct a wide variety of ComeUnity-
ReEngineering seminars and workshops on topics ranging from Juvenile Justice
to Parental Rights, to Domestic issues to Police friendly contacts, to mental
health intervention, to CBO and FBO accountability and compliance;
4. Throughout the process, we encourage and maintain frequent personal contact
between all parties;
5 Throughout the process we conduct a continuum of events and fundraisers
designed to facilitate collaboration among professionals and community
stakeholders; and finally
6. 1 We disseminate Quarterly publications, like our e-Advocate series Newsletter
and our e-Advocate Quarterly electronic Magazine to all regular donors in order
to facilitate a lifelong learning process on the ever-evolving developments in the
Justice system.
And in addition to the help we provide for our young clients and their families, we also
facilitate Community Engagement through the Restorative Justice process,
thereby balancing the interests of local businesses, schools, clergy, social assistance
organizations, elected officials, law enforcement entities, and all interested
stakeholders. Through these efforts, relationships are rebuilt & strengthened, local
businesses and communities are enhanced & protected from victimization, young
careers are developed, and our precious young people are kept out of the prison
pipeline.
Additionally, we develop Transformative “Void Resistance” (TVR) initiatives to elevate
concerns of our successes resulting in economic hardship for those employed by the
penal system.
TVR is an innovative-comprehensive process that works in conjunction with our
Transformative Justice initiatives to transition the original use and purpose of current
systems into positive social impact operations, which systematically retrains current
staff, renovates facilities, creates new employment opportunities, increases salaries and
is data proven to enhance employee’s mental wellbeing and overall quality of life – an
exponential Transformative Social Impact benefit for ALL community stakeholders.
1 In addition to supporting our world-class programming and support services, all regular donors receive our Quarterly e-Newsletter
(The e-Advocate), as well as The e-Advocate Quarterly Magazine.
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This is a massive undertaking, and we need all the help and financial support you can
give! We plan to help 75 young persons per quarter-year (aggregating to a total of 250
per year) in each jurisdiction we serve) at an average cost of under $2,500 per client,
per year. *
Thank you in advance for your support!
* FYI:
1. The national average cost to taxpayers for minimum-security youth incarceration,
is around $43,000.00 per child, per year.
2. The average annual cost to taxpayers for maximum-security youth incarceration
is well over $148,000.00 per child, per year.
- (US News and World Report, December 9, 2014);
3. In every jurisdiction in the nation, the Plea Bargain rate is above 99%.
The Judicial system engages in a tri-partite balancing task in every single one of these
matters, seeking to balance Rehabilitative Justice with Community Protection and
Judicial Economy, and, although the practitioners work very hard to achieve positive
outcomes, the scales are nowhere near balanced where people of color are involved.
We must reverse this trend, which is right now working very much against the best
interests of our young.
Our young people do not belong behind bars.
- Jack Johnson
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The Advocacy Foundation, Inc.
Helping Individuals, Organizations & Communities
Achieve Their Full Potential
The EDTC Incubator
for Transformative Social Impact ®
“Turning the Improbable Into the Exceptional”
Atlanta
Philadelphia
______
John C. Johnson III
Founder & CEO
Mark L. Merrill
Northeast Regional Director
(878) 222-0450
Voice | Data | SMS
www.TheAdvocacy.Foundation
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Biblical Authority
______
Proverbs 11:14 (NIV)
14
For lack of guidance a nation falls, but victory is won through many advisers.
Proverbs 15:22
22
Plans fail for lack of counsel, but with many advisers they succeed.
Proverbs 16:9
9
In their hearts humans plan their course, but the Lord establishes their steps.
Acts 20:35
35
In everything I did, I showed you that by this kind of hard work we must help the
weak, remembering the words the Lord Jesus himself said: ‘It is more blessed to give
than to receive.’ ”
Galatians 6:9
9
Let us not become weary in doing good, for at the proper time we will reap a harvest if
we do not give up.
1 Corinthians 15:58
58
Therefore, my dear brothers and sisters, stand firm. Let nothing move you. Always
give yourselves fully to the work of the Lord, because you know that your labor in the
Lord is not in vain.
Luke 14:28
28
“Suppose one of you wants to build a tower. Won’t you first sit down and estimate the
cost to see if you have enough money to complete it?
Mark 10:42-45
42
Jesus called them together and said, “You know that those who are regarded as
rulers of the Gentiles lord it over them, and their high officials exercise authority over
them. 43 Not so with you. Instead, whoever wants to become great among you must be
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your servant, 44 and whoever wants to be first must be slave of all. 45 For even the Son of
Man did not come to be served, but to serve, and to give his life as a ransom for many.”
Habakkuk 2:2
The Lord’s Answer
2
Then the Lord replied: “Write down the revelation and make it plain on tablets so that a
herald may run with it.
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Table of Contents
The EDTC Incubator
for Transformative Social Impact
Biblical Authority
I. INTRODUCTION: The EDTC Incubator…………………………………… 17
II.
ORGANIZING
The 501(c)(3) Acquisition Process………………………………………… 23
Transformative Community Engagement
and Multidisciplinary Collaboration ……………………………….. 31
Organizational Development & Sustainability …………………………… 33
III.
PLANNING
Strategic Planning …………………………………………………………... 37
Evidence-Based Programming ……………………………………………. 38
Data-Driven Resource Allocation ………………………………………….. 41
IV.
SUSTAINABILITY & COMPLIANCE
Economic Emancipation & Fundraising …………………………………... 43
- UBIT Initiatives
Best Practices and Accountability ………………………………………… 44
Compliance ………………………………………………………………...... 45
V. CRITICAL THINKING for TRANSFORMATIVE SOCIAL IMPACT
Paradigm Shifting & Change Management ……………………………… 49
Inner-City Strategic Revitalization Planning…………………………….... 53
________
Attachments
A. 501(c)(3) Compliance Guide (rev. 3-2018 (p4221pc))
B. Quick Short-Term Impact Analysis (2-2018)
C. EDTC Incubator Workshop Budget
Copyright © 2003-2018 The Advocacy Foundation, Inc. All Rights Reserved.
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Introduction
The EDTC Incubator
The Entrepreneurial Development Center (EDTC)
Incubator was established to helps new, startup, and
existing organizations to form and grow by providing
services such as organizational development
training, capacity-building, community engagement
expertise and much more.
The National Business Incubation Association (NBIA)
defines [such] incubators as a catalyst tool for either
regional or national economic development. NBIA
categorizes their [own] members’ incubators by the
following five incubator types: academic institutions; nonprofit
development corporations; for-profit property
development ventures; venture capital firms, and [various]
combinations of the above.
[Such] incubators differ from research and technology parks in their dedication to startup
and early-stage [organizations]. Research and technology parks, on the other hand,
tend to be large-scale projects that house everything from corporate, government or
university labs to very small companies. Most research and technology parks do not
offer business assistance services, which are the hallmark of business incubation
programs. However, many research and technology parks house incubation programs.
Incubators also differ from the U.S. Small Business Administration's Small Business
Development Centers (and similar business support programs) in that they serve only
selected clients. SBDCs are required by law to offer general business assistance to any
company that contacts them for help. In addition, SBDCs work with any small business
at any stage of development, not only startup companies. Many business incubation
programs partner with their local SBDC to create a "one-stop shop" for entrepreneurial
support.
Within European Union countries there are different EU and state funded programs that
offer support in form of consulting, mentoring, prototype creation and other services and
co-funding for them. TecHub is one of examples for IT companies and ideas.
History
The formal concept of business incubation began in the USA in 1959 when Joseph L.
Mancuso opened the Batavia Industrial Center in a Batavia, New York, warehouse.
Incubation expanded in the U.S. in the 1980s and spread to the UK and Europe through
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various related forms (e.g. innovation centres, pépinières d’entreprises,
technopoles/science parks).
The U.S.-based International Business Innovation Association estimates that there are
about 7,000 incubators worldwide. A study funded by the European Commission in
2002 identified around 900 incubation environments in Western Europe.
As of October 2006, there were more than 1,400 incubators in North America, up from
only 12 in 1980. Her Majesty's Treasury identified around 25 incubation environments in
the UK in 1997; by 2005, UKBI identified around 270 incubation environments across
the country.
In 2005 alone, North American incubation programs assisted more than 27,000
companies that provided employment for more than 100,000 workers and generated
annual revenues of $17 billion.
Incubation activity has not been limited to developed countries; incubation environments
are now being implemented in developing countries and raising interest for financial
support from organizations such as UNIDO and the World Bank.
Types of Services
Since startup companies lack many resources, experience and networks, incubators
provide services which helps them get through initial hurdles in starting up a business.
These hurdles include space, funding, legal, accounting, computer services and other
prerequisites to running the business.
Among the most common incubator services are:
Help with business basics
Networking activities
Marketing assistance
Market Research
High-speed Internet access
Help with accounting/financial management
Access to bank loans, loan funds and guarantee programs
Help with presentation skills
Links to higher education resources
Links to strategic partners
Access to angel investors or venture capital
Comprehensive business training programs
Advisory boards and mentors
Management team identification
Help with business etiquette
Technology commercialization assistance
Help with regulatory compliance
Intellectual property management
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Types
There are a number of business incubators that have focused on particular industries or
on a particular business model, earning them their own name.
This list is incomplete:
Virtual business incubator - online business incubator
Kitchen incubator - a business incubator focused on the food industry
Public incubator - a business incubator focused on the public good
Seed accelerator - a business incubator focused on early startups
Corporate accelerator - a program of a larger company that acts akin to a seed
accelerator
Startup studio - a business incubator with interacting portfolio companies
Hybrid Incubator - A business incubator that combines virtual incubator with onpremise
activities
Industry Sectors Intentionally Supported By Incubation Programs
Technology Creative industries Construction
Computer software eBusiness / eCommerce Arts
Services/professional Wireless technology Aerospace
Manufacturing Healthcare technology Kitchen/Food
Internet Advanced materials Retail
Biosciences/life sciences Defense/homeland security Fashion
Electronics/Microelectronics Energy/Power Wood/forestry
Telecommunications Environment/clean technologies Tourism
Computer hardware Logistics/Delivery Manpower
Medical devices Nanotechnology Media
More than half of all business incubation programs are "mixed-use" projects, meaning
they work with clients from a variety of industries. Technology incubators account for
39% of incubation programs.
One example of a specialized type of incubator is a bioincubator. Bioincubators
specialize in supporting life science-based startup companies. Entrepreneurs with
feasible projects in life sciences are selected and admitted for these programs.
The Incubation Process
Overview
Unlike many business assistance programs, business incubators do not serve any and
all companies. Entrepreneurs who wish to enter a business incubation program must
apply for admission. Acceptance criteria vary from program to program, but in general
only those with feasible business ideas and a workable business plan are admitted. It is
this factor that makes it difficult to compare the success rates of incubated companies
against general business survival statistics.
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Although most incubators offer their clients office space and shared administrative
services, the heart of a true business incubation program are the services it provides to
startup companies. More than half of incubation programs surveyed by the National
Business Incubation Association in 2006 reported that they also served affiliate or virtual
clients. These companies do not reside in the incubator facility. Affiliate clients may be
home-based businesses or early-stage companies that have their own premises but can
benefit from incubator services. Virtual clients may be too remote from an incubation
facility to participate on site, and so receive counseling and other assistance
electronically.
The amount of time a company spends in an incubation program can vary widely
depending on a number of factors, including the type of business and the entrepreneur's
level of business expertise. Life science and other firms with long research and
development cycles require more time in an incubation program than manufacturing or
service companies that can immediately produce and bring a product or service to
market. On average, incubator clients spend 33 months in a program. Many incubation
programs set graduation requirements by development benchmarks, such as company
revenues or staffing levels, rather than time.
Goals and Sponsors
Business incubation has been identified as a means of meeting a variety
of economic and socioeconomic policy needs, which may include job creation, fostering
a community's entrepreneurial climate, technology commercialization, diversifying local
economies, building or accelerating growth of local industry clusters, business creation
and retention, encouraging women or minority entrepreneurship, identifying potential
spin-in or spin-out business opportunities, or community revitalization.
About one-third of business incubation programs are sponsored by economic
development organizations. Government entities (such as cities or counties) account for
21% of program sponsors. Another 20% are sponsored by academic institutions,
including two- and four-year colleges, universities, and technical colleges. In many
countries, incubation programs are funded by regional or national governments as part
of an overall economic development strategy. In the United States, however, most
incubation programs are independent, community-based and resourced projects. The
U.S. Economic Development Administration is a frequent source of funds for developing
incubation programs, but once a program is open and operational it typically receives no
federal funding; few states offer centralized incubator funding. Rents and/or client fees
account for 59% of incubator revenues, followed by service contracts or grants (18%)
and cash operating subsidies (15%).
As part of a major effort to address the ongoing economic crisis of the US, legislation
was introduced to "reconstitute Project Socrates". The updated version of Socrates
supports incubators by enabling users with technology-based facts about the
marketplace, competitor maneuvers, potential partners, and technology paths to
achieve competitive advantage. Michael Sekora, the original creator and director of
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Socrates says that a key purpose of Socrates is to assist government economic
planners in addressing the economic and socioeconomic issues (see above) with
unprecedented speed, efficiency and agility.
Many for-profit or "private" incubation programs were launched in the late 1990s by
investors and other for-profit operators seeking to hatch businesses quickly and bring in
big payoffs. At the time, NBIA estimated that nearly 30% of all incubation programs
were for-profit ventures. In the wake of the dot-com bust, however, many of those
programs closed. In NBIA's 2002 State of the Business Incubation survey, only 16% of
responding incubators were for-profit programs. By the 2006 SOI, just 6% of
respondents were for-profit.
Although some incubation programs (regardless of nonprofit or for-profit status) take
equity in client companies, most do not. Only 25% of incubation programs report that
they take equity in some or all of their clients.
Incubator Networks
Incubators often aggregate themselves into networks which are used to share good
practices and new methodologies. Europe's European Business and Innovation Centre
Network ("EBN") association federates more than 250 European Business and
Innovation Centres (EU|BICs) throughout Europe. France has its own national network
of technopoles, pre-incubators, and EU|BICs, called RETIS Innovation. This network
focuses on internationalizing startups.
Of 1000 incubators across Europe, 500 are situated in Germany. Many of them are
organized federally within the ADT (Arbeitsgemeinschaft Deutscher Innovations-,
Technologie-, und Gründerzentren e.V.).
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II. Organizing
The 501(c)(3) Acquisition Process
Overview
To [qualify for] tax-exempt [status] under
section 501(c)(3) of the Internal Revenue
Code, an organization must be organized
and operated exclusively for exempt
purposes set forth in section 501(c)(3),
and none of its earnings may inure to any
private shareholder or individual. In
addition, it may not be an action
organization, i.e., it may not attempt to
influence legislation as a substantial part
of its activities and it may not participate
in any campaign activity for or against
political candidates.
Organizations described in section
501(c)(3) are commonly referred to as
charitable organizations. Organizations
described in section 501(c)(3), other than
testing for public safety organizations,
are eligible to receive tax-deductible
contributions in accordance with Code
section 170.
The organization must not be organized
or operated for the benefit of private interests, and no part of a section 501(c)(3)
organization's net earnings may inure to the benefit of any private shareholder or
individual. If the organization engages in an excess benefit transaction with a person
having substantial influence over the organization, an excise tax may be imposed on the
person and any organization managers agreeing to the transaction.
Section 501(c)(3) organizations are restricted in how much political and legislative
(lobbying) activities they may conduct.
______
A 501(c) organization, also known colloquially as a 501(c), is a tax-exempt nonprofit
organization in the United States. Section 501(c) of the United States Internal Revenue
Code (26 U.S.C. § 501(c)) provides that 29 types of nonprofit organizations are exempt
from some federal income taxes. Sections 503 through 505 set out the requirements for
attaining such exemptions. Many states refer to Section 501(c) for definitions of
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organizations exempt from state taxation as well. 501(c) organizations can receive
unlimited contributions from individuals, corporations, and unions.
The most common type of tax-exempt nonprofit organization falls under category
501(c)(3), whereby a nonprofit organization is exempt from federal income tax if its
activities have the following purposes: charitable, religious, educational, scientific,
literary, testing for public safety, fostering amateur sports competition, or preventing
cruelty to children or animals. The 501(c)(4) and 501(c)(6) categories are for politically
active nonprofits, which have become increasingly important since the 2004 presidential
election.
________
Charitable Organizations and Private Foundations
501(c)(3) exemptions apply to corporations, and any community chest, fund,
cooperating association or foundation, organized and operated exclusively for religious,
charitable, scientific, literary, or educational purposes, or for testing for public safety, or
to foster national or international amateur sports competition, or for the prevention of
cruelty to children or animals. There are also supporting organizations—often referred
to in shorthand form as "Friends of" organizations.
Another provision, 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, among others. Regulations specify which such
deductions must be verifiable to be allowed (e.g., receipts for
donations over $250). Due to the tax deductions associated
with donations, loss of 501(c)(3) status can be highly challenging to a charity's
continued operation, as many foundations and corporate matching programs do not
grant funds to a charity without such status, and individual donors often do not donate to
such a charity due to the unavailability of the deduction.
Testing for public safety is described under section 509(a)(4) of the code, which makes
the organization a public charity and not a private foundation, but contributions to
509(a)(4) organizations are not deductible by the donor for federal income, estate, or
gift tax purposes.
The two exempt classifications of 501(c)(3) organizations are as follows:
A public charity, identified by the Internal Revenue Service (IRS) as "not a private
foundation", normally receives a substantial part of its income, directly or
indirectly, from the general public or from the government. The public support
must be fairly broad, not limited to a few individuals or families. Public charities
are defined in the Internal Revenue Code under sections 509(a)(1) through
509(a)(4).
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A private foundation, sometimes called a non-operating foundation, receives
most of its income from investments and endowments. This income is used to
make grants to other organizations, rather than being disbursed directly for
charitable activities. Private foundations are defined in the Internal Revenue
Code under section 509(a) as 501(c)(3) organizations, which do not qualify as
public charities.
Churches must meet specific requirements in order to obtain and maintain tax exempt
status; these are outlined in IRS Publication 1828: Tax guide for churches and religious
organizations. This guide outlines activities allowed and not allowed by churches under
the 501(c)(3) designation. A private,
nonprofit organization, GuideStar, also
provides information on 501(c)(3)
organizations.
Before donating to a 501(c)(3)
organization, a donor may wish to
consult the searchable online IRS list of
charitable organizations as well as lists that may be maintained by a state on a portion
of its web portal devoted to its "department of justice" or "office of attorney general".
Consumers may file IRS Form 13909 with documentation to complain about
inappropriate or fraudulent (i.e., fundraising, political campaigning, lobbying) activities
by any 501(c)(3) tax-exempt organization.
Obtaining Status
The basic requirement of obtaining tax exempt status is that the organization is
specifically limited in powers to purposes that the IRS classifies as tax exempt
purposes. Unlike for-profit corporations that benefit from broad and general purposes,
non profit organizations need to be limited in powers to function with tax exempt status,
but a non profit corporation is by default not limited in powers until it specifically limits
itself in the articles of incorporation and/or nonprofit corporate bylaws. This limiting of
the powers is crucial to obtaining tax exempt status with the IRS and then on the state
level. Organizations acquire 501(c)(3) tax exemption by filing IRS Form 1023. As of
2006 the form must be accompanied by a $850 filing fee if the yearly gross receipts for
the organization are expected to average $10,000 or more. If yearly gross receipts are
expected to average less than $10,000, the filing fee is reduced to $400. There are
some classes of organizations that automatically are treated as tax exempt under
501(c)(3), without the need to file Form 1023:
Churches, their integrated auxiliaries, and conventions or associations of
churches
Organizations that are not private foundations and that have gross receipts that
normally are not more than $5,000
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The IRS also expects to release a software tool called Cyber Assistant, which assists
with preparation of the application for tax exemption, but as of late 2011 the release
date is unclear.
There is an alternative way for an organization to obtain status if an organization has
applied for a determination and either there is an actual controversy regarding a
determination or the Internal Revenue Service has failed to make a
determination. In these cases, the
United States Tax Court, the
United States District Court for the District of
Columbia, and the United States Court of
Federal Claims have
concurrent jurisdiction
to issue a declaratory judgment of the
organization's
qualification if the organization
has exhausted administrative remedies with
the Internal Revenue
Service.
Political Activity
Section 501(c)(3) organizations are
prohibited from supporting political candidates,
and are subject to limits on lobbying. They risk
loss of tax exempt status if these rules are
violated. An organization that loses
its 501(c)(3) status due
to being engaged in
political activities cannot then qualify for
501(c)(4) status.
Elections
Organizations described in section 501(c)(3) are prohibited from conducting political
campaign activities to intervene in elections to public office. The Internal Revenue
Service website elaborates upon this prohibition as follows:
Under the Internal Revenue Code, all section 501(c)(3) organizations are absolutely
prohibited from directly or indirectly participating in, or intervening in, any political
campaign on behalf of (or in opposition to) any candidate for elective public office.
Contributions to political campaign funds or public statements of position (verbal or
written) made on behalf of the organization in favor of or in opposition to any candidate
for public office clearly violate the prohibition against political campaign activity.
Violating this prohibition may result in denial or revocation of tax-exempt status and the
imposition of certain excise taxes.
Certain activities or expenditures may not be prohibited depending on the facts and
circumstances. For example, certain voter education activities (including presenting
public forums and publishing voter education guides) conducted in a non-partisan
manner do not constitute prohibited political campaign activity. In addition, other
activities intended to encourage people to participate in the electoral process, such as
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voter registration and get-out-the-vote drives, would not be prohibited political campaign
activity if conducted in a non-partisan manner.
On the other hand, voter education or registration activities constitute prohibited
participation or intervention if there is evidence of bias that would:
Favor one candidate over another
Oppose a candidate in some manner
Have the effect of favoring a candidate or group of candidates
The Internal Revenue Service provides resources to exempt organizations and the
public to help them understand the prohibition. As part of its examination program, the
IRS also monitors whether organizations are complying with the prohibition.
Lobbying
In contrast to the prohibition on political campaign interventions by all section 501(c)(3)
organizations, public charities (but not private foundations) may conduct a limited
amount of lobbying to influence
legislation. Although the law
states that "No substantial part..." of a public charity's
activities can go to lobbying,
charities with large budgets
may lawfully expend a million
dollars (under the
"expenditure" test),
or more (under the "substantial part"
test) per year on
lobbying.
To clarify the standard of the
"substantial part" test, the
United States Congress enacted §501(h), called the
Conable election after its author,
Representative Barber Conable. The section
establishes limits based on
operating budget that a
charity can use to determine
if it meets the substantial
test.
This changes the prohibition against direct intervention in partisan contests only for
lobbying. The organization is now presumed in compliance with the substantiality test if
they work within the limits.
The Conable election requires a charity to file a declaration with the IRS and file a
functional distribution of funds spreadsheet with their Form 990. IRS form 5768 is
required to make the Conable election.
________
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Step-by-Step
Nonprofit Incorporation Code
Most states have some form of legislated Business Incorporation Code governing the
formation and administration of Nonprofit organizations. Georgia Nonprofit activities, for
example, are governed by O.C.G.A. §14-3-101, et seq. The statute, governs the
formation, operation and dissolution of nonprofit corporations within the state. A
nonprofit corporation in Georgia, as in most other states, is managed by its board of
directors and operated by its officers and employees. Instead of shareholders, a
nonprofit corporation may, but is not required to, have members. Nonprofit corporations
are specifically organized not to earn profits. Moreover, no part of the income or surplus
of a Georgia nonprofit corporation may be distributed to its members, directors or
officers; however, reasonable compensation may be paid to employees or consultants
for services rendered.
Articles of Incorporation
The Articles of Incorporation are the most fundamental, as well as the beginning, part of
the business creation process. This document specifically enumerates the basics under
which the organization will operate and it provides the foundational standard under
which the business is ultimately held accountable for its corporate actions and operating
processes. Nonprofit corporations must be organized exclusively for charitable,
educational, social/human service, and/ or community economic development
purposes.
Organizational By-Laws
By-Laws are a bit more specific. They “zero-in” on Membership, Board of Director
activities, and Policy creation and enforcement within the organization. Board Officers
and Duties are often set forth within the By-Laws, as well as the Amendment
procedures for making organizational policy changes. All Board officers should sign the
By-Laws at or around the time of the organizational meeting to demonstrate
organizational cohesiveness at its inception.
Board of Directors
Board responsibilities can be enormous, depending on the complexity and mission of
the organization being created. Moreover, there may be liability for Board Officers for
which an insurance policy should be obtained. Board Member Terms of Office should
also be addressed with all other initial considerations, and these terms should be
enumerated within the organization’s By-Laws to eliminate any potential confusion or
disagreements following program implementation. A Schedule of Board Meetings
should be set forth in the By-Laws, and a Board Manual should be created and
distributed to each Board Member so that scheduling and expectations are clear to
everyone and advance notice is provided as early in the life of the program as possible.
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Program Staff
Specific personnel need not be named
prior to the submittal of the
501(c)(3) application, however Specific
Positions must be set forth in the
application. In addition, Salaries, Tax
Rates and Benefit Costs must also be
included. And don’t forget that bonuses
and additional compensation items such
as profit sharing, and other such
incentives commonly used as privatesector
motivational techniques, should not
be offered to nonprofit staff members.
The bulk of the monies taken in through
donations, grants, etc. should be used for
Service Delivery, Capacity Building,
Community Collaboration, Administration
and Services, and other Pre-Approved
Items and Services.
Conflict of Interest Policy
The purpose of the Conflicts policy is to
protect the organization’s interest when entering into any arrangement that could
potentially or directly benefit a private interest of an officer or director, or result in an
“excess benefit” transaction. Such transactions are specifically prohibited by State and
Federal statutes.
Program Narrative
The Program Narrative is perhaps the most challenging part of the 501(c)(3) process. It
sets forth in great detail precisely how the program will operate, including both
background for its existence as well as day-to-day operations and procedures. The
more clearly and specific this section of the application is developed, the greater the
likelihood of unhindered approval at the federal level.
Organizational Budget
A great Program Budget will match and support all aspects of the Program Narrative
and the activities set forth in the narrative. It must be painstakingly developed, and it
must be carried out to the letter in order to avoid even an appearance of impropriety at
the Corporate level. Ideally, once developed, the Program Budget should be reviewed
by a finance expert, such as an Attorney or CPA for both approval and also to initiate
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the basis for annual financial audits, which will greatly enhance the organizations ability
to attract ongoing and re-occuring funding.
IRS Form 1023
The Application for Exemption itself is not overly complicated, however the responses to
particular questions, and the financial projections that must be disclosed must be
accurate.
They must also agree with and support the activities set forth in the Program Narrative
and Budget sections. Moreover, there are generally twelve (12) relevant pages with
questions that must be meticulously addressed, and, depending upon the type of
organization being created and exempted, there are specific Schedules that may have
to be completed as well.
Planned Fundraising Activities
Finally, it’s important that you disclose all of your intended methods for raisingfunds.
Below is a partial, but by no means exhaustive, list of fundraising activities that most
nonprofits and churches engage in on a regular basis.
Planned Fundraising activities should always include, but by no means be limited to, the
following: Government Grant Writing; Foundation Grant Development; Website
Donation Solicitations; Events; E-Mail Solicitations (where permitted); Mail solicitations
(where permitted); and Other solicitations as planned periodically.
Application Fees
Application fees for the 501(c)(3) application has been streamlined. The current
processing fee is $650.00 US.
Processing a 501(c)(3) application can take several months, and in some cases, more
than a year. Generally speaking, however, the greater the effort at the inception of the
program, the less likely there will be delays in successfully processing the application
once the process has been initiated.
For these reasons, it is strongly recommended and advised that you seek the help and
advice of a professional when processing your 501(c)(3) application. Doing so should
not only help to insure a successful application, it can also greatly minimize the time it
will take to get the application processed and approved.
________
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Transformative Community Engagement
and Multidisciplinary Collaboration
Transformative Community
Engagement refers to the process
by which community benefit organizations
and individuals build ongoing, permanent
relationships for the purpose of applying
a collective vision for the benefit of a
community. While community organizing
involves the process of building a
grassroots movement involving
communities, community engagement
primarily deals with the practice of
moving said communities towards
change, usually from a stalled or
otherwise similarly suspended position.
Community engagement can trace its
roots to the concept of community
benefit, a term that grew out of an English
common law concept, articulated in an
1891 legal decision that defined four
types of charitable organizations: trusts
for the advancement of education; trusts
for the advancement of religion; and
trusts for other purposes beneficial to the community.
As community benefit became an important method of institutionalizing ideals, methods
evolved to effectively reach the communities those entities were meant to aid. This led
to the birth of community organizing, which as far as the United States is concerned,
gained momentum over time beginning in the late 1800s. Practitioners of community
engagement runs the gamut, from local community members to professionals such as
business developers or social workers. Additionally, they can be specific to issues, such
as grassroots organizers focusing on economic justice, or rehabilitation counselors
focusing on disability-related issues.
Methodologies of community engagement are a result of problems in the current
community benefit administrative structure, where governing boards of community
projects become unable to continue convincing either themselves or the community to
further the projects they became involved in. This may be due to "incorrect aiming of
accountability for problems in the governing board, overzealous micromanagement of
resources, a collectively dysfunctional board, poor board / staff relations or
unsatisfactory organizational planning." Because of these overlaying problems,
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community members themselves are also directly influenced and therefore similarly
hindered in regards to change within their specific regions of development.
Civic engagement refers to political activity, membership and volunteering in civil
society organizations. Social engagement refers to participation in collective activities.
Community engagement refers to the process by which community benefit
organizations and individuals build ongoing, permanent relationships for the purpose of
applying a collective vision for the benefit of a community.
Practical community engagement is used as an active method of implementing change.
While most current standards implore more static means through standard marketing
techniques, community engagement involves actively implementing a specific
process towards activism such as
the 8-step guideline listed below
developed by Hildy Gottlieb of
Creating the Future. While the
process may have similarities to a
controversial form of friendraising, the
emphasis in community
engagement is that of
honest relationship building for the sake of
community, not for
the sole purpose of
money-making.
The steps are:
1. Determine the goals of the
plan
2. Plan out who to engage
3. Develop engagement
strategies for those individuals you already know
4. Develop engagement strategies of those individuals you do not already know
5. Prioritize those activities
6. Create an implementation plan
7. Monitor your progress
8. Maintain those relationships
Other programs exist to assist communities in the process of building community
coalitions for engagement. One such program is Communities That Care which helps
communities assess their needs and implement tested and effective programs to
address their identified issues.
Key Concepts
Community engagement may involve the use of particular key concepts relevant to the
community benefit sector such as:
Friendraising
Community impact planning
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Community-driven governance
Asset-based resource development
Vision-based community impact planning
Organizational wellness planning
Building programs on shared resources
Community sleuthing
Community-based program development
________
Organizational Development
and Sustainability
Is Nonprofit Sustainability A Reality? 7
The nonprofit landscape is changing and
you’re faced with a real challenge. You
want to create impact and build a
sustainable future for your nonprofit. But
is it really possible? Experts say, yes! In
fact, Jeanne Bell, Jan Masaoka and
Steve Zimmerman, authors of Nonprofit
Sustainability: Making Strategic Decisions
for Financial Viability, say that when
nonprofits begin to understand how to
bring programmatic goals together with
financial goals, they’ll start to make
decisions that lead to organizational
sustainability.
These experts say that sustainable
nonprofits follow these core principles:
1. Financial
Sustainability. Sustainable
nonprofits always tie impact goals
to financial goals. Remember,
fiscal health and the maintenance
of adequate working capital is as intrinsic to success over the long term as
community impact is.
2. Effective Management of Hybrid Revenue Strategies. Nonprofits today are
supported by diverse sources. Many nonprofits are looking at alternative
revenue-producing models to mitigate funding cuts. Management of hybrid
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strategies can be a challenge. For this reason, different financial goals must be
set for different revenue streams and each must be managed in a different way.
3. Development of An Explicit Nonprofit Business Model. Strategic business
decisions can’t be made without an existing business model. For this reason,
every nonprofit needs to develop a viable business strategy that brings together
all of the organization’s activities under the umbrella of the organization’s
mission. In the nonprofit world, programmatic impact strategies will be a
significant part of the business model. But each activity should be associated not
only with an impact strategy but also a revenue strategy. Thus, the sustainable
nonprofit has a “dual bottom-line” – impact and financial return.
4. Continuous Decision-Making. Today’s nonprofits face unprecedented
challenges. Evaluation, assessment and continuous decision-making are
necessary for survival and success when change is constant.
You should also keep in mind that succession planning is also a critical aspect of
sustainability because it ensures that staff, leadership and board members don’t take
critical knowledge and relationships with them when they leave.
________
What Nonprofit Functions Are [Typically]
Most In Need of Strengthening?
Nonprofits are typically organized into major functional areas, such as: central
administration, governance,
and programming. To be
sustainable over the long term, each
functional area must operate efficiently
and effectively and
take its place as
part of the whole.
The problem arises when cutbacks, programmatic
shifts, changing funder and
donor needs and the like,
take the stage. In such cases,
resource-strapped nonprofits
are stretched too thin. As a result, less essential
functions may become neglected and begin to
weaken. This, in turn, affects the
organization’s ability to fulfill its
mission.
According to a recent
study by the Weingart Foundation,
today’s nonprofits identify the following functions as most in need of attention:
Board Leadership and Development
The need for a strong nonprofit board cannot be overstated. Board members connect
the community with an organization’s mission, vision and values. As stewards, they
educate the community about the organization’s work and they support the organization
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with resources needed to fulfill its mission. They hold the organization accountable, and
provide fiscal oversight. Many nonprofits are struggling to recruit members who can help
move their mission forward and, once recruited, they are unsure of how to keep boards
active and participating. For tips on keeping your board engaged, see Boards and
Governance.
Program Evaluation and Strategic Learning
Nonprofits recognize the need to regularly assess and evaluate programs and
operations in order to better target to their constituency, maintain morale and keep their
organizations energized. Unfortunately, many of these nonprofits are simply
overwhelmed keeping programs running. As a result they forgo the evaluation and
learning opportunities necessary to help build a more sustainable operation. To learn
about how you can easily incorporate program evaluation and strategic learning into
your nonprofit, read Strategic Planning and Evaluation.
Human Resource Development
Nonprofits need to focus on leadership transition. They need to find new ways to recruit
and cultivate “next generation” organizational leaders. They also need to build capacity
to recruit and keep talent and supply the technical resources necessary to carry out
their work. To learn about strengthening your HR function, see Managing People.
Financial Management
Nonprofits need to build the financial capacity necessary to maintain organizational
stability. And financial viability is key. A stable nonprofit is able to adapt to changing
environments and more effectively serve the community. To learn about building
financial capacity, read Finance.
Fundraising
Though nonprofits and their boards often understand the impact of fundraising in
maintaining a strong, sustainable organization, they may think that bringing more dollars
in the door is the single answer to their problems. As a result, they underemphasize the
need to integrate fundraising with marketing and communications, board governance,
evaluation, HR and financial management. In Fundraising, and Marketing &
Communications, you’ll learn more about amplifying fundraising and communications by
building strong functions in every area.
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III. Planning
Strategic Planning
Strategic Planning is an
organization's process of defining its
strategy, or direction, and making
decisions on allocating its resources to
pursue this strategy, including its capital
and people. Various business analysis
techniques can be used in strategic
planning, including:
1. SWOT analysis (Strengths,
Weaknesses, Opportunities, and
Threats);
2. PEST analysis (Political,
Economic, Social, and
Technological);
3. STEER analysis (Socio-cultural,
Technological, Economic,
Ecological, and Regulatory
factors); and
4. EPISTEL (Environment, Political,
Informatic, Social, Technological, Economic and Legal).
Strategic planning is the formal consideration of an organization's future course. All
strategic planning deals with at least one of three key questions:
1. "What do we do?"
2. "For whom do we do it?"
3. "How do we excel?"
In business strategic planning, some authors phrase the third question as "How can we
beat or avoid competition?". (Bradford and Duncan, page 1). But this approach is more
about defeating competitors than about excelling.
In many organizations, this is viewed as a process for determining where an
organization is going over the next year or - more typically - 3 to 5 years (long term),
although some extend their vision to 20 years.
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In order to determine where it is going, the organization needs to know exactly where it
stands, then determine where it wants to go and how it will get there. The resulting
document is called the "strategic plan."
While strategic planning may be used to effectively plot a company's longer-term
direction, one cannot use it to reliably forecast how the market will evolve and what
issues will surface in the immediate future. Therefore, strategic innovation and tinkering
with the 'strategic plan' have to be a cornerstone strategy for an organization to survive
the turbulent business climate.
Evidence-Based Programming
The Importance of Evidence Based
Social Interventions
Non-governmental and governmental organizations worldwide implement programs to
combat social problems, including poverty and lack of adequate health care. However,
the programs are often designed and executed based on assumptions rather than
based on data and facts. In her TED talk entitled “Social Experiments to Fight Poverty,”
MIT economist Esther Duflo compares the implementation of social programs that are
not evidence based to the use of leeches by doctors in the medieval period.
Doctors used leeches due to prevailing assumptions about the body and illness during
that period. Sometimes the leeches worked, but they were oftentimes ineffective. In
some cases, the leeches caused blood loss that exacerbated the patient’s condition.
Centuries later, evidence-based medicine and rigorous analysis became central to
medical practice. Until recently, social policies and interventions have been developed
and implemented based on assumptions rather than evidence. Evidence-based [Social
Interventions] are [now] essential.
The nonprofit organization Innovations For Poverty Action further explains that “Two
voids exist in developmental policy: insufficient incorporation of results from social
science research, and insufficient evaluation (in particular, replication of studies) to
learn concretely what works, what does not, and why.”
Some organizations and research centers have recently begun conducting evaluations
of various interventions to determine their efficacy in practice rather than in theory.
Their overall goal is to positively influence the design and implementation of policies
and programs by international organizations, non-governmental organizations, and
governments.
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Design of Evaluations and Sample Interventions
When developing new interventions or programs, it is important for program
implementers to utilize existing research to determine “how people make financial
decisions, adopt new technology, use social networks to help survive crises, respond to
incentives, decide how much education to acquire, etc.” This application of academic
theory is needed to develop sample interventions. Evans et al. note that “Better
understanding of the barriers (at the
person, family and provider level) is
essential before strategies can be
devised, and these strategies need to be
evaluated carefully. Only then can we
know if we are doing more good than
harm and spending limited resources
wisely.” Abdul Latif Jameel Poverty Action
Lab in Boston integrates social and
behavioral sciences and public health
research, which were previously primarily
confined to academia, into policy design.
This type of important research allows
program designers and implementers to
determine the expected efficiency,
effectiveness, and potential impact of a
new program idea prior to implementation.
After a program has been implemented, it
is crucial to implement ongoing
assessments and evaluations.
Randomized evaluations, which are used
extensively by the Abdul Latif Jameel
Poverty Action Lab (J-PAL), are a type of
impact evaluation. A randomized evaluation may also be known as randomized
controlled trials, social experiments, random assignment studies, randomized field trials,
and randomized controlled experiments. J-PAL emphasizes that randomized study
designs provide the most accurate, unbiased, and reliable statistics out of all other
impact evaluation options. In order to determine a program’s impact, it is essential to
have a randomly-selected control group of participants who are statistically identical to
the experimental group. Both of the groups are considered microcosms of the larger
population and therefore equal in representation to each other. When applying this
design, any changes between the control and experimental group can be attributed
almost solely to the effects of the program. For more information on randomization and
reliable data, see Validity of Research and Quality Health Data.
The Purpose of Evaluation
Abdul Latif Jameel Poverty Action Lab discusses the goals of evaluation: "If thoughtfully
designed and implemented, it [randomized evaluation] can answer the questions, how
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effective was it? Were there unintended side-effects? Who benefitted most? Who was
harmed? Why did it work or not work? What lessons can be applied to other contexts,
or if the program was scaled up? How cost-effective was the program? How does it
compare to other programs designed to accomplish similar goals?"
After randomized evaluations have been conducted on test interventions and have
answered these chief questions, the results can be utilized by program designers and
program implementers. Based on the research and considerations of context,
policymakers can decide which interventions are best to scale up. Evidence-based
social interventions maximize positive social outcomes and ensure that policies and
programs are effective rather than harmful to the target population. Foreign aid
interventions illustrate the necessity of both of these goals. For generations, the debate
on foreign aid has been wrought with controversy, mostly because evidence has not
been developed or analyzed to assess impact. For example, Duflo notes that we do not
know whether Africa would be better off now if we had given more aid or less aid since
1970. Without supporting evidence, implementation of policies and interventions can
be a waste of resources or worse, exacerbate social problems.
Evidence-based practice (EBP) is an interdisciplinary approach to clinical practic that
has been gaining ground following its formal introduction in 1992. It started in medicine
as evidence-based medicine (EBM) and spread to other fields such as dentistry,
nursing, psychology, education, library and information science. Its basic principles are
that 1) all practical decisions should be made based upon research studies and 2) that
these research studies are to be selected and interpreted according to some specific
norms characteristic for EBP. Typically such norms disregard both theoretical and
qualitative studies and consider quantitative studies according to a narrow set of criteria
of what counts as evidence. If such a narrow set of methodological criteria are not
applied, it is considered better just to speak instead of research based practice.
Evidence-based behavioral practice (EBBP) "entails making decisions about how to
promote health or provide care by integrating the best available evidence with
practitioner expertise and other resources, and with the characteristics, state, needs,
values and preferences of those who will be affected. This is done in a manner that is
compatible with the environmental and organizational context. Evidence is research
findings derived from the systematic collection of data through observation and
experiment and the formulation of questions and testing of hypotheses".
Empirically supported treatments (ESTs) in some clinical settings are defined as "clearly
specified psychological treatments shown to be efficacious in controlled research with a
delineated population"
Social Policy
There are increasing demands for the whole range of social policy and other decisions
and programs run by government and the NGO sector to be based on sound evidence
as to their effectiveness. This has seen an increased emphasis on the use of a wide
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ange of Evaluation approaches directed at obtaining evidence about social programs of
all types. A research collaboration called the Campbell Collaboration has been set up in
the social policy area to provide evidence for evidence-based social policy decisionmaking.
This collaboration follows the approach pioneered by the Cochrane
Collaboration in the health sciences. Using an evidence-based approach to social policy
has a number of advantages because it has the potential to decrease the tendency to
run programs which are socially acceptable (e.g. drug education in schools) but which
often prove to be ineffective when evaluated.
Data-Driven Resource Allocation
Data-Informed Decision-Making (DIDM)
DDDM refers to the collection and
analysis of data to guide decisions that
improve success. DIDM is used in
education communities (where data is
used with the goal of helping students)
but is also applicable to (and thus also
used in) other fields in which data is used
to inform decisions. While data-driven
decision-making is a more common term,
data-informed decision-making is a
preferable term since decisions should
not be based solely on quantitative data.
Most educators have access to a data
system for the purpose of analyzing
student data. These data systems
present data to educators in an over-thecounter
data format (embedding labels,
supplemental documentation, and a help
system, making key package/display and
content decisions) to improve the success
of educators’ data-informed decisionmaking.
Decision making has long been a subject of study and given the explosive growth of Big
Data over the past decade, it’s not surprising that data-driven decision making is one of
the most promising applications in the emerging discipline of data science.
In a recently published article, “Data Science and its Relationship to Big Data and Data-
Driven Decision Making,” Foster Provost and Tom Fawcett define data-driven decision
making as “the practice of basing decisions on the analysis of data rather than purely on
intuition.” Equally succinctly, they view data science “as the connective tissue between
data-processing technologies (including those for big data) and data-driven decision
making.”
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One of the biggest challenges in leveraging data science to help make complex
strategic decisions is to mistakenly assume that an unordered, unpredictable, complex
context is in fact an ordered, predicable complicated one. “This assumption, grounded
in the Newtonian science that underlies scientific management, encourages
simplifications that are useful in ordered circumstances. Circumstances change,
however, and as they become more complex, the simplifications can fail. Good
leadership is not a one-size-fits-all proposition.”
Neither is good data-driven decision making. With operational decisions, we have to
learn to distinguish between those situations when decisions can be embedded in
automated processes, and those that require human intervention. With strategic
decisions we have to learn the difference between complicated but predictable contexts,
and complex and intrinsically unpredictable ones. This is all part of what makes data
science such an important and exciting discipline.
- Irving Wladawsky-Berger
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IV. Sustainability & Compliance
Economic Emancipation
and Fundraising
Just as Reverend Leon H. Sullivan once
embraced the idea of Economic
Emancipation for people of color, we
must now embrace its logical extension,
Economic Emancipation for our
Community and Faith-Based
organizations, many of which arose out
of the very movement embraced by our
predecessors, in order to help them
more fully fulfill their manifest destinies.
During the most recent recession, many
of our charitable organizations suffered
near-fatal setbacks. Most have yet to
fully recover, and, unfortunately, some
will not ever recover. But there are
important lessons-learned in order to
prevent the same thing from happening
all over again one day. And as we move
forward, we must now help them not only
to recover, but learn to thrive as well,
even in the aftermath of the devastating
losses. We must help these
organizations break the dependency on government funding and develop their own
ability to operate and raise funds independently, while simultaneously helping them
learn to “think outside the box” with regard to their sustainability and survival.
This project is designed to do exactly that. It is a natural extension of the Sullivan
movement of the prior eras when those individuals who pressed-forward to achieve their
own economic emancipation evolved their causes, as well as their communities, into
powerful forces, economically, which are right now under attack and in imminent danger
of being eradicated right out of existence.
- Jack Johnson
______
“The genius of America has been in the nation’s ability to solve our greatest problems:
whether it be in the expansion of frontiers, the building of cities, or putting a man on the
moon. In the past there has been no problem too great for America to solve.”
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- Rev. Dr. Leon H. Sullivan
A New American Alliance
(Speech given at the 8 th annual OIC Convocation, Washington, DC)
Alternatives to Despair, p.82 (1972)
______
In tackling any problem, our objective should be to deal with depth causes...
But we must go deeper still. Our need is to reach further and further down, deeper even
than OIC. Millions of Americans must be reached in the briefest period of time in a
massive, carefully expedited program of adult incentive education...
- Rev. Dr. Leon H. Sullivan
AAE: Americanizing America
Build Brother Build, p.143 (1969)
________
Best Practices and Accountability
A Best Practice is a method or technique that has been generally accepted as
superior to any alternatives because it produces results that are superior to those
achieved by other means or because it has become a standard way of doing things,
e.g., a standard way of complying with legal or ethical requirements.
Best practices are used to maintain quality as an alternative to mandatory legislated
standards and can be based on self-assessment or benchmarking. Best practice is a
feature of accredited management standards such as ISO 9000 and ISO 14001.
Some consulting firms specialize in the area of best practice and offer pre-made
templates to standardize business process documentation. Sometimes a best practice
is not applicable or is inappropriate for a particular organization's needs. A key strategic
talent required when applying best practice to organizations is the ability to balance the
unique qualities of an organization with the practices that it has in common with others.
Good operating practice is a strategic management term. More specific uses of the term
include good agricultural practices, good manufacturing practice, good laboratory
practice, good clinical practice and good distribution practice.
But Will It Work Here?
The final step in identifying an appropriate best practice for a policy problem is to ensure
that the context from which the practice is derived is comparable to the context in which
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Charity/Nonprofit Sector
it will be applied. Risks to implementing
the selected best practice in the applied
context as well as what support
structures can be put in place need to be
anticipated in order to maximize the
likelihood of success. If utilizing a pilot or
demonstration program "best practice"
the success of that practice needs to be
discounted in order to account for the
better than average favorable conditions
pilot and demonstration programs usually
operate under. These conditions include
increased enthusiasm, advantageous
political and economic conditions, and
less bureaucratic resistance due to the
lack of permanency in pilot programs.
Finally, when considering implementing a
"best practice" on a wide scale one must
be aware of the weakest link sites with
minimal to no resources and how those
sites will be supported in order to create
the desired policy outcomes.
The nonprofit/voluntary sector is generally lacking tools for sharing and accessing best
practices. Steps are being taken in some parts of the world, for example in the
European Union, where the Europe 2020 Strategy has as a top priority the exchange of
good practices and networking (including the nonprofit sector).
An initiative of sharing good practices in terms of human resources (HR) and leadership
among European nonprofit organizations was financed by the EU and launched in 2013,
called HR Twinning. The platform allows the public to search for good practices and its
members the possibility to share their practices, engage in discussions in the forum
section and enroll their organization. Membership is free. The project is currently limited
to a European audience.
________
Compliance
In general, compliance means conforming to a rule, such as a specification, policy,
standard or law. Regulatory compliance describes the goal that organizations aspire
to achieve in their efforts to ensure that they are aware of and take steps to comply with
relevant laws and regulations.
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Due to the increasing number of regulations and need for operational transparency,
organizations are increasingly adopting the use of consolidated and harmonized sets of
compliance controls. This approach is used to ensure that all necessary governance
requirements can be met without the unnecessary duplication of effort and activity from
resources.
Standards and Regulations
The International Organization for Standardization (ISO) produces international
standards such as ISO/IEC_27002. The International Electro-technical Commission
(IEC) produces international standards in the electro-technology area. The ISO
19600:2014 standard provides a reminder of how compliance and risk should operate
together, as “colleagues” sharing a common framework with some nuances to account
for their differences.
Some local or international specialized organizations such as the American Society of
Mechanical Engineers (ASME) also develop standards and regulation codes. They
thereby provide a wide range of rules and directives to ensure compliance of the
products to safety, security or design standards.
There are a number of other regulations which apply in different fields, such as PCI-
DSS, GLBA, FISMA, Joint Commission and HIPAA. In some cases other compliance
frameworks (such as COBIT) or standards (NIST) inform on how to comply with the
regulations.
USA
Corporate scandals and breakdowns such as the Enron case of reputational risk in
2001 have highlighted the need for stronger compliance and regulations for publicly
listed companies. The most significant regulation in this context is the Sarbanes–Oxley
Act developed by two U.S. congressmen, Senator Paul Sarbanes and Representative
Michael Oxley in 2002 which defined significantly tighter personal responsibility of
corporate top management for the accuracy of reported financial statements.
The Office of Foreign Assets Control (OFAC) is an agency of the United States
Department of the Treasury under the auspices of the Under Secretary of the Treasury
for Terrorism and Financial Intelligence. OFAC administers and enforces economic and
trade sanctions based on U.S. foreign policy and national security goals against
targeted foreign states, organizations, and individuals.
Compliance in the USA generally means compliancy with laws and regulations. These
laws can have criminal or civil penalties or can be regulations. The definition of what
constitutes an effective compliance plan has been elusive. Most authors, however,
continue to cite the guidance provided by the United States Sentencing Commission in
Chapter 8 of the Federal Sentencing Guidelines.
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On October 12, 2006, the U.S. Small Business Administration re-launched
Business.gov (new Business.USA.gov) which provides a single point of access to
government services and information that help businesses comply with government
regulations.
Challenges
Data retention is a part of regulatory
compliance that is proving to be a
challenge in many instances. The
security that comes from compliance
with industry regulations can seem
contrary to maintaining user privacy.
Data retention laws and regulations ask
data owners and other service
providers to retain extensive records of
user activity beyond the time necessary
for normal business operations. These
requirements have been called into
question by privacy rights advocates.
Compliance in this area is becoming
very difficult. Laws like the CAN-SPAM
Act and Fair Credit Reporting Act in the
U.S. require that businesses give
people the “right to be forgotten.” In
other words, they must remove
individuals from marketing lists if it is
requested, tell them when and why they
might share personal information with a third party, or at least ask permission before
sharing that data. Now, with new laws coming out that demand longer data retention
despite the individual’s desires, it can create some real difficulties.
Definitions
Compliance data is defined as all data belonging or pertaining to enterprise or included
in the law, which can be used for the purpose of implementing or validating compliance.
It is the set of all data that is relevant to a governance officer or to a court of law for the
purposes of validating consistency, completeness, or compliance. Compliance software
is increasingly being implemented to help company's manage their compliance data
more efficiently.
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Page 48 of 89

V. Critical Thinking
for Transformative Social Impact
Paradigm Shifting
and Change Management
Critical Thinking
Disciplined thinking that is clear, rational,
open-minded, and informed by evidence.
- Dictionary.com
________
The National Council for Excellence in
Critical Thinking defines it as the
intellectually disciplined process of actively
and skillfully conceptualizing, applying,
analyzing, synthesizing, and/or evaluating
information gathered from, or generated by,
observation, experience, reflection,
reasoning, or communication, as a guide to
belief and action.
Critical thinking is a rich concept that has
been developing throughout the past 2500
years. The term "Critical Thinking" has its
roots in the mid-late 20th century. [There
are] overlapping definitions [that] form a
substantive, trans-disciplinary conception of
critical thinking.
Critical Thinking as Defined by
The National Council for Excellence in
Critical Thinking (1987)
A statement by Michael Scriven & Richard Paul, presented at the 8th Annual
International Conference on Critical Thinking and Education Reform (Summer 1987)
Critical thinking is the intellectually disciplined process of actively and skillfully
conceptualizing, applying, analyzing, synthesizing, and/or evaluating information
gathered from, or generated by, observation, experience, reflection, reasoning, or
communication, as a guide to belief and action. In its exemplary form, it is based on
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universal intellectual values that transcend subject matter divisions: clarity, accuracy,
precision, consistency, relevance, sound evidence, good reasons, depth, breadth, and
fairness.
It entails the examination of those structures or elements of thought implicit in all
reasoning: purpose, problem, or question-at-issue; assumptions; concepts; empirical
grounding; reasoning leading to conclusions; implications and consequences;
objections from alternative viewpoints; and frame of reference.
Critical thinking — in being responsive to variable subject matter, issues, and
purposes — is incorporated in a family of interwoven modes of thinking, among them:
scientific thinking, mathematical thinking, historical thinking, anthropological thinking,
economic thinking, moral thinking, and philosophical thinking.
Critical thinking can be seen as having two components:
1. A set of information and belief generating and processing skills, and
2. The habit, based on intellectual commitment, of using those skills to guide
behavior.
It is thus to be contrasted with:
1. The mere acquisition and retention of information alone, because it involves a
particular way in which information is sought and treated;
2. The mere possession of a set of skills, because it involves the continual use of them;
and
3. The mere use of those skills ("as an exercise") without acceptance of their results.
Critical thinking varies according to the motivation underlying it. When grounded in
selfish motives, it is often manifested in the skillful manipulation of ideas in service of
one’s own, or one's groups’, vested interest. As such it is typically intellectually flawed,
however pragmatically successful it might be. When grounded in fair-mindedness and
intellectual integrity, it is typically of a higher order intellectually, though subject to the
charge of "idealism" by those habituated to its selfish use.
Critical thinking of any kind is never universal in any individual; everyone is subject to
episodes of undisciplined or irrational thought. Its quality is therefore typically a matter
of degree and dependent on, among other things, the quality and depth of experience in
a given domain of thinking or with respect to a particular class of questions. No one is a
critical thinker through-and-through, but only to such-and-such a degree, with
such-and-such insights and blind spots, subject to such-and-such tendencies
towards self-delusion.
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For this reason, the development of critical thinking skills and dispositions is a life-long
endeavor.
Another Brief Conceptualization of Critical Thinking
Critical thinking is self-guided, self-disciplined thinking which attempts to reason at the
highest level of quality in a fair-minded way.
People who think critically consistently attempt to live rationally, reasonably, empathically.
They are keenly aware of the inherently flawed nature of human thinking when left
unchecked. They strive to diminish the power of their egocentric and sociocentric
tendencies. They use the intellectual tools that critical thinking offers – concepts and
principles that enable them to analyze, assess, and improve thinking. They work
diligently to develop the intellectual virtues of intellectual integrity, intellectual humility,
intellectual civility, intellectual empathy, intellectual sense of justice and confidence in
reason. They realize that no matter how skilled they are as thinkers, they can always
improve their reasoning abilities and they will at times fall prey to mistakes in reasoning,
human irrationality, prejudices, biases, distortions, uncritically accepted social rules and
taboos, self-interest, and vested interest. They strive to improve the world in whatever
ways they can and contribute to a more rational, civilized society. At the same time,
they recognize the complexities often inherent in doing so. They avoid thinking
simplistically about complicated issues and strive to appropriately consider the rights and
needs of relevant others. They recognize the complexities in developing as thinkers,
and commit themselves to life-long practice toward self-improvement. They embody the
Socratic principle: The unexamined life is not worth living , because they realize that
many unexamined lives together result in an uncritical, unjust, dangerous world.
Why Critical Thinking?
The Problem
- Linda Elder, September, 2007
Everyone thinks; it is our nature to do so. But much of our thinking, left to itself, is
biased, distorted, partial, uninformed or down-right prejudiced. Yet the quality of our life
and that of what we produce, make, or build depends precisely on the quality of our
thought. Shoddy thinking is costly, both in money and in quality of life. Excellence in
thought, however, must be systematically cultivated.
A Definition
Critical thinking is that mode of thinking - about any subject, content, or problem - in
which the thinker improves the quality of his or her thinking by skillfully taking charge of
the structures inherent in thinking and imposing intellectual standards upon them.
The Result
A well cultivated critical thinker:
Raises vital questions and problems, formulating them clearly and precisely;
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Gathers and assesses relevant information, using abstract ideas to interpret it
effectively comes to well-reasoned conclusions and solutions, testing them
against relevant criteria and standards;
Thinks openmindedly within alternative systems of thought, recognizing and
Assessing, as need be, their assumptions, implications, and practical
consequences; and
Communicates effectively with others in figuring out solutions to complex
problems.
Critical thinking is, in short, self-directed, self-disciplined, self-monitored, and selfcorrective
thinking. It presupposes assent to rigorous standards of excellence and
mindful command of their use. It entails effective communication and problem solving
abilities and a commitment to overcome our native egocentrism and sociocentrism.
- Richard Paul and Linda Elder: The Miniature Guide to Critical Thinking Concepts and
Tools
Foundation for Critical Thinking Press, 2008
Critical Thinking Defined
by Edward Glaser
In a seminal study on critical thinking and education in 1941, Edward Glaser defines
critical thinking as follows “The ability to think critically, as conceived in this volume,
involves three things:
1. An attitude of being disposed to consider in a thoughtful way the problems and
subjects that come within the range of one's experiences;
2. Knowledge of the methods of logical inquiry and reasoning; and
3. Some skill in applying those methods.
Critical thinking calls for a persistent effort to examine any belief or supposed form of
knowledge in the light of the evidence that supports it and the further conclusions to
which it tends. It also generally requires ability to recognize problems, to find workable
means for meeting those problems, to gather and marshal pertinent information, to
recognize unstated assumptions and values, to comprehend and use language with
accuracy, clarity, and discrimination, to interpret data, to appraise evidence and
evaluate arguments, to recognize the existence (or non-existence) of logical
relationships between propositions, to draw warranted conclusions and generalizations,
to put to test the conclusions and generalizations at which one arrives, to reconstruct
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one's patterns of beliefs on the basis of wider experience, and to render accurate
judgments about specific things and qualities in everyday life.
- Edward M. Glaser, An Experiment in the Development of Critical Thinking,
Teacher’s College, Columbia University, 1941)
________
Inner-Cities Strategic
Revitalization Planning
Revitalization
Neighborhood Revitalization starts at the
grassroots level — with people in the
community determining the goals for their
neighborhood.
______
It is defined as the process of making
something grow, develop, or become
successful again (e.g. A new indoor
sports arena has played a key role in the
revitalization of its neighborhood).
- Cambridge Dictionaries Online
“Neighborhood Revitalization is the
way of the future and is an essential
element of [our] work. By focusing on
entire neighborhoods, we can greatly
increase our impact.”
— Jonathan Reckford, CEO,
Habitat for Humanity International
Revitalization of Our Inner-Cities Can Transform Our Culture
- by Scruffus
“It is only when the basic needs are met that culture can thrive. Revitalization of our
inner-cities is the innovation that will allow for maximum cultural growth in this country.
Making sure that all Americans have access to opportunity and technology will ensure
future generations of city dwellers do not live in poverty. By investing in these areas,
developers and businesses are investing in the base of this country. Music, art and the
sciences require a healthy, vibrant, and supportive community and the work being done
to rebuild our inner cities is essential to our culture[s] as a whole.”
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Spanning the Delaware River, the “Trenton Makes” Bridge in giant neon red letters
proclaims to all, "Trenton Makes, The World Takes.". Hearkening back to the time
when Trenton was a center of manufacture, these days the sign seems a bit of an
anachronism. Trenton and many other American cities have decayed to the point that
they are shells of their former selves. Businesses and people slowly disappeared from
American cities over the decades since the sixties. No longer centers of thriving
industry, they are now crime-ridden, politically corrupt, and decaying. Despite this, cities
are now the focus of revitalization efforts. If done properly, revitalization can be a way to
alleviate the poverty and crime suffered in many American inner cities. Revitalization is
a recent innovation that takes advantage of the existing enterprise and infrastructure in
cities and tries to bring value back to the community there. Efforts to revitalize cities
meet with varied success.
It is important to elevate the standard of living for the existing community, not
just shove it aside in the pursuit of a gentrified city. Giving the existing people a
chance at independence raises the standard of living for all residents in the city
and preserves the rich heritage and character of the city.
In the effort to attract people back to the cities, revitalization increases the
independence of all Americans, utilizes existing infrastructure, and encourages cultural
growth.
One cannot speak of a city's and a people's
independence without speaking of their economic
independence. The ability of people to obtain jobs
and meet their basic needs is a huge determinant
of how well that people's culture will flourish. It is
difficult to pursue the arts or education if one is
impoverished. The rebuilding of inner cities can
raise the quality of life for many Americans by
bringing businesses that provide jobs and
opportunity back to the cities. Also, a city that has
a thriving business community has a healthy tax
base to support its public education system. The
public school is an integral part of revitalization.
Providing students with a high-quality, technologybased
education prepares them to become
successful, contributing citizens. Inner city school
systems are notorious for their high dropout rates
and general difficulty in producing good students.
By revitalizing inner cities, parents are given
access to jobs and can provide a better home environment for their children.
The use of existing infrastructure in revitalization efforts reduces suburban sprawl.
Areas that were long ago developed for housing and business are made attractive
through remodeling, which is less costly and environmentally destructive than building
new homes in the suburbs. Encouraging city living also encourages use of mass transit
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systems, decreasing reliance on the automobile. Our current culture is very much
entwined with the automobile. Reduction of our reliance on automobiles is beneficial in
reducing pollutants. Additionally, inner cities have often been characterized as food
deserts, where nutritious, low-cost food is difficult to find because large supermarkets
refuse to build there. Hopefully with the influx of jobs and money to the cities,
supermarkets will follow. Bringing new life to cities will definitely improve the options
available to all residents there.
Cities are where culture, technology and the arts can flourish. The exchange of ideas
and open-mindedness to these ideas occurs because of the cosmopolitan nature of
cities. By renewing interest in our cities, we can create dynamic centers of innovation
and technology that are not found in our suburbs. Suburban living has long been cliched
to have sapped the creativity and vitality from our society. There is a grain of truth to
this. Suburbanites often do not meet their neighbors and spend a great deal of time
driving to their destinations. Urban areas, by design, force people to interact with their
surroundings. It is this interaction that allows the acceptance of new ideas that build up
culture.
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Attachment A
501c3 Compliance Guide
(rev. 3-2018 (p4221pc))
Page 59 of 89

01(c)(3)
Tax Exempt and Government Entities
EXEMPT ORGANIZATIONS
01(c)(3)
Compliance Guide
for 501(c)(3)
Public Charities,
Inside:
Activities that may jeopardize
01(c)(3)
a charity’s exempt status,
Federal information returns, tax
returns or notices that must be filed,
Recordkeeping—why, what, when,
Governance considerations,
Changes to be reported to the IRS,
01(c)(3)
Required public disclosures,
Resources for public charities,

Contents
What Activities May Jeopardize a
Public Charity’s Tax-Exempt Status? ......................................................................................4
Private Benefit and Inurement ......................................................................................................4
Political Campaign Intervention ...................................................................................................4
Legislative Activities .....................................................................................................................7
What Federal Information Returns,
Tax Returns and Notices Must be Filed? ...............................................................................8
Form 990, Return of Organization Exempt From Income Tax, Form 990-EZ,
Short Form Return of Organization Exempt From Income Tax and Form 990-N,
Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required To
File Form 990 or 990-EZ ..............................................................................................................8
Form 990 and Form 990-EZ ....................................................................................................... 10
Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not
Required to File Form 990 or 990-EZ ........................................................................................ 11
Form 990-T, Exempt Organization Business Income Tax Return ............................................. 12
1
Employment Tax Returns ........................................................................................................... 13
Why Keep Records? .....................................................................................................................14
Evaluate Charitable Programs .................................................................................................... 15
Monitor Budgetary Results ........................................................................................................ 15
Prepare Financial Statements .................................................................................................... 15
Prepare Annual Information and Tax Returns ............................................................................ 15
Identify Sources of Receipts ...................................................................................................... 15
Substantiate Revenues, Expenses and Deductions
for Unrelated Business Income Tax (UBIT) Purposes ............................................................... 15
Comply with Grant-Making Procedures (Grants to Individuals) ............................................... 16
Comply with Racial Nondiscrimination Requirements (Private Schools) ................................. 16
What Records Should be Kept? ...............................................................................................16
Accounting Periods and Methods ............................................................................................. 18
Supporting Documents .............................................................................................................. 18
How Long Should Records be Kept? .....................................................................................18
Record Retention Periods .......................................................................................................... 19

What Governance Procedures and Practices Should
an Organization Consider Adopting or Have In Place? ...................................................19
Mission Statement and Organizational Documents .................................................................. 19
Governing Body .......................................................................................................................... 19
Governance and Management Policies .....................................................................................20
Financial Statements and Information Reporting ......................................................................20
Transparency ..............................................................................................................................20
How Should Changes be Reported to the IRS? ................................................................ 20
Reporting Changes on the Annual Information Return .............................................................20
Determination Letters and Private Letter Ruling Requests .......................................................20
What Disclosures are Required? ............................................................................................ 21
Public Inspection of Annual Returns and Exemption Applications .......................................... 21
Sale of Free Government Information ........................................................................................23
Charitable Contributions—Substantiation and Disclosure .......................................................23
How Do You Get IRS Assistance and Information? ......................................................... 25
2
Specialized Assistance for Tax-Exempt Organizations .............................................................25
Tax Publications for Exempt Organizations ...............................................................................26
Forms for Exempt Organizations ...............................................................................................26
General IRS Assistance ..............................................................................................................27

Compliance Guide for 501(c)(3)
Public Charities
Federal tax law provides tax benefits to nonprofit organizations recognized as exempt
from federal income tax under Internal Revenue Code (IRC) Section 501(c)(3). The IRC
requires that tax-exempt organizations must comply with federal tax law to maintain tax-exempt
status and avoid penalties.
3
In this publication, the IRS addresses activities that could jeopardize a public charity’s
tax-exempt status. It identifies general compliance requirements on recordkeeping, reporting
and disclosure for exempt organizations described in IRC Section 501(c)(3) that are classified
as public charities. This publication is neither comprehensive nor intended to address every
situation.
To learn more about compliance rules and procedures that apply to public charities exempt
from federal income tax under Section 501(c)(3), see IRS Publication 557, Tax-Exempt Status
for Your Organization, and the Life Cycle of a Public Charity. Also, stay abreast of new EO
information by signing up for the Exempt Organizations Update, a free e-newsletter for
tax-exempt organizations and tax practitioners who represent them. For further assistance,
consult a tax adviser.

What Activities May Jeopardize a
Public Charity’s Tax-Exempt Status?
Once a public charity has completed the application process and has established
that it is exempt under Section 501(c)(3), the charity’s officers, directors, trustees and
employees must ensure that the organization maintains its tax-exempt status and
meets its ongoing compliance responsibilities.
A 501(c)(3) public charity that does not restrict its participation in certain activities
and does not absolutely refrain from others, risks failing the operational test and
jeopardizing its tax-exempt status. The following summarizes the limitations on the
activities of public charities.
Private Benefit and Inurement
A public charity is prohibited from allowing more than an insubstantial accrual of
private benefit to individuals or organizations. This restriction is to ensure that a taxexempt
organization serves a public interest, not a private one. If a private benefit is
more than incidental, it could jeopardize the organization’s tax-exempt status.
No part of an organization’s net earnings may inure to the benefit of an insider. An
insider is a person who has a personal or private interest in the activities of the
organization such as an officer, director or a key employee. This means that an
organization is prohibited from allowing its income or assets to accrue to insiders.
An example of prohibited inurement would include payment of unreasonable
compensation to an insider. Any amount of inurement may be grounds for loss of taxexempt
status.
4
If a public charity provides an economic benefit to any person who is able to
exercise substantial influence over its affairs (that exceeds the value of any goods
or services provided in consideration), the organization has engaged in an excess
benefit transaction. A public charity that engages in an excess benefit transaction
must report it to the IRS. Excise taxes are imposed on any person who engages in
an excess benefit transaction with a public charity, and on any organization manager
who knowingly approves the transaction. (See Reporting Excess Benefit
Transactions on page 11).
A public charity that becomes aware that it may have engaged in an excess benefit
transaction should consult a tax advisor and take appropriate action to avoid any
potential impact it could have on the organization’s tax-exempt status. Visit
www.irs.gov/charities-non-profits for details about inurement, private benefit and
excess benefit transactions.
Political Campaign Intervention
Public charities are prohibited from directly or indirectly participating in, or intervening
in, any political campaign on behalf of (or in opposition to) any candidate for elective
public office. Contributions to political campaign funds or public statements of

position (verbal or written) made on behalf of the organization in favor of, or in
opposition to, any candidate for public office clearly violate the prohibition against
political campaign activity. Violation of this prohibition may result in revocation of
tax-exempt status and/or imposition of certain excise taxes.
Certain activities or expenditures may not be prohibited depending on the facts
and circumstances. For example, certain voter education activities (including
the presentation of public forums and the publication of voter education guides)
conducted in a non-partisan manner do not constitute prohibited political
campaign activity. Other activities intended to encourage people to participate in
the electoral process, such as voter registration and get-out-the-vote drives, would
not constitute prohibited political campaign activity if conducted in a non-partisan
manner. On the other hand, voter education or registration activities conducted in
a biased manner that favors one candidate over another, opposes a candidate in
some manner or has the effect of favoring a candidate or group of candidates, will
constitute prohibited campaign intervention.
The political campaign activity prohibition is not intended to restrict free
expression on political matters by leaders of public charities speaking for
themselves as individuals. However, for their organizations to remain tax exempt
under Section 501(c)(3), organization leaders cannot make partisan comments in
official organization publications or at official functions. When speaking in a nonofficial
capacity, these leaders should clearly indicate that their comments are
personal, and not intended to represent the views of the organization.
5
Some Section 501(c)(3) organizations take positions on public policy issues,
including issues that divide candidates in an election for public office. However,
Section 501(c)(3) organizations must avoid any issue advocacy that functions as
political campaign intervention. Even if a statement does not expressly tell an
audience to vote for or against a specific candidate, an organization delivering the
statement is at risk of violating the political campaign intervention prohibition if
there is any message favoring or opposing a candidate. A statement can identify
a candidate not only by stating the candidate’s name but also by other means
such as showing a picture of the candidate, referring to political party affiliations
or other distinctive features of a candidate’s platform or biography. All the facts
and circumstances need to be considered to determine if the advocacy is political
campaign intervention.
The IRS considers the following factors that tend to show an advocacy
communication is political campaign activity:
■■ whether the statement identifies one or more candidates for a given
public office,
■■ whether the statement expresses approval or disapproval for one or more
candidates’ positions and/or actions,
■■ whether the statement is delivered close in time to the election,

■■ whether the statement refers to voting or an election,
■■ whether the issue addressed in the communication has been raised as an
issue distinguishing candidates for a given office,
■■ whether the communication is part of an ongoing series of communications by
the organization on the same issue that are made independent of the timing of
any election, and,
■■ whether the timing of the communication and identification of the candidate
are related to a non-electoral event such as a scheduled vote on specific
legislation by an officeholder who also happens to be a candidate for public
office.
A communication is particularly at risk of political campaign intervention when it
refers to candidates or voting in a specific upcoming election. Nevertheless, the
communication must still be considered in context before arriving at any conclusions.
Political candidates may be invited to appear or speak at organization events in
their capacity as candidates, or in their individual capacity (not as a candidate).
Candidates may also appear without an invitation at organization events that are
open to the public.
When candidates are invited to speak at a public charity’s event in their capacity
as political candidates, factors in determining whether the organization participated
or intervened in a political campaign include:
■■ whether the public charity provides an equal opportunity to participate to the
political candidates seeking the same office,
■■ whether the public charity indicates any support of, or opposition to, the
candidate (including candidate introductions and communication concerning
the candidate’s attendance), and
■■ whether any political fundraising occurs.
6
When a candidate is invited to speak at a public charity’s event in a non-candidate
capacity, factors in determining whether the candidate’s appearance results in a
political campaign intervention for the organization include:
■■ whether the individual is chosen to speak solely for reasons other than
candidacy for public office,
■■ whether the individual speaks only in a non-candidate capacity or references
his or her candidacy or the election,
■■ whether the individual or any representative of the organization makes any
mention of the individual’s candidacy or the election,
■■ whether any campaign activity occurs in connection with the individual’s
appearance,
■■ whether the organization maintains a nonpartisan atmosphere on the premises
or at the event where the individual is present, and
■■ whether the organization clearly indicates the capacity in which the individual
is appearing and does not mention the individual’s political candidacy or
the upcoming election in the communications announcing the indivdual’s
attendance at the event.

In determining whether candidates are given an equal opportunity to participate,
the nature of the event to which each candidate is invited, should be considered
in addition to the manner of presentation. For example, a public charity that
invites one candidate to speak at its well-attended annual banquet, but invites the
opposing candidate to speak at a sparsely attended general meeting, will likely
violate the political campaign prohibition, even if the manner of presentation for
both speakers is otherwise neutral.
Sometimes a public charity invites several candidates to speak at a public forum.
A public forum involving several candidates for public office may qualify as an
exempt educational activity. However, if the forum is operated to show a bias for
or against any candidate, then the forum would be prohibited campaign activity, as
it would be considered intervention or participation in a political campaign. When
an organization invites several candidates for the same office to speak at a forum,
determining whether the forum results in political campaign intervention include:
■■ whether questions for the candidate are prepared and presented by an
independent nonpartisan panel;
■■ whether the topics discussed by the candidates cover a broad range of issues
that the candidates would address if elected to the office sought and are of
interest to the public;
■■ whether each candidate is given an equal opportunity to present his or her
views on the issues discussed;
■■ whether the candidates are asked to agree or disagree with positions,
agendas, platforms or statements of the organization; and
■■ whether a moderator comments on the questions or otherwise implies
approval or disapproval of the candidates.
7
Revenue Ruling 2007-41 provides additional information on the prohibition against
political campaign intervention.
Legislative Activities
A public charity is not permitted to engage in substantial legislative activities
(commonly known as lobbying). An organization will be regarded as attempting
to influence legislation if it contacts, or urges the public to contact, members or
employees of a legislative body for purposes of proposing, supporting or opposing
legislation, or advocates the adoption or rejection of legislation.
If lobbying activities are substantial, a 501(c)(3) organization may fail the operational
test and risk losing its tax-exempt status and/or be liable for excise taxes.
Substantiality is measured by either the substantial part test or the expenditure
test. The substantial part test determines substantiality based on all the facts and
circumstances in each case. The IRS considers a variety of factors, including the
time devoted (by both compensated and volunteer workers) and expenditures
devoted by the organization to the activity, when determining whether the lobbying
activity is substantial.
As an alternative, a public charity (other than a church) may elect to use the
expenditure test by filing Form 5768, Election/Revocation of Election by an Eligible

Section 501(c)(3) Organizations To Make Expenditures To Influence Legislation.
Under the expenditure test, the extent of a public charity’s lobbying activities will
not jeopardize its tax-exempt status, provided its expenditures, related to the
activities do not normally exceed a set amount specified in IRC Section 4911. This
limit is generally based on the size of the organization and may not exceed $1
million.
Also, under the expenditure test, a public charity that engages in excessive
lobbying activity over a four-year period may lose its tax-exempt status, making
all its income for that period subject to tax. Should the organization exceed its
lobbying expenditure dollar limit in a year, it must pay an excise tax equal to
25 percent of the excess. Visit the Life Cycle of a Public Charity for additional
information about the rules against substantial legislative activities.
Public charities that engage in lobbying activities must report lobbying activities on
Form 990, Schedule C, Political Campaign and Lobbying Activities.
What Federal Information Returns,
Tax Returns and Notices Must be Filed?
While 501(c)(3) public charities are exempt from federal income tax, most of these
organizations have information reporting obligations under the IRC to ensure that
they continue to be recognized as tax-exempt. In addition, they may also be liable
for employment taxes, unrelated business income tax, excise taxes and certain
state and local taxes.
8
Form 990, Return of Organization Exempt From Income Tax, Form
990-EZ, Short Form Return of Organization Exempt From Income
Tax and Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt
Organizations Not Required To File Form 990 or 990-EZ
Public charities generally file either a:
■■
Form 990, Return of Organization Exempt From Income Tax,
■■ Form 990-EZ, Short Form Return of Organization Exempt From Income Tax, or
■■
Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not
Required To File Form 990 or 990-EZ.
The type of Form 990 series return a public charity must file is generally
determined by the organization’s financial activity as indicated in the chart below.
Filing Dates
Forms 990, 990-EZ and 990-N must be filed by the 15th day of the fifth month
after the end of the organization’s tax year. The due date for the Forms 990
and 990-EZ may be automatically extended for six months by filing Form 8868,
Application for Automatic Extension of Time To File an Exempt Organization
Return, before the due date.
An organization cannot request an extension for filing the Form 990-N; however,
there is no penalty for filing it late.
See Filing Penalties and Revocation of Tax-Exempt Status on page 12.

Gross Receipts Thresholds,
Gross receipts normally ≤ $50,000,
Form
to File,
990-N,
Gross receipts < $200,000
990-EZ
and Total assets < $500,000, or 990,
Gross receipts ≥ $200,000 or Total assets ≥ $500,000 990,
Filing Exceptions
Public charities not required to file an annual information return
include certain:
■■ religious organizations;
■■ governmental organizations;
■■ political organizations;
■■ organizations that file different kinds of annual information returns;
■■ subordinate organizations included in a group return filed by the central
organization; and
■■ organizations whose annual gross receipts are normally $50,000 or less and,
therefore, are eligible to file an annual electronic notice (see Form 990-N,
Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required
To File Form 990 or 990-EZ on page 11).
If a public charity is excepted from filing a Form 990 or Form 990-EZ because
annual gross receipts are normally $50,000 or less, and it elects to file the Form
990 or Form 990-EZ, it must complete the entire return. An organization that only
completes those items of information on the Form 990 or Form 990-EZ that are
required to be provided on an electronic Form 990-N will not be deemed to have
met its electronic notice requirement.
9
Special Requirements for Supporting
Organizations and Donor Advised Funds
Public charities that are supporting organizations described in Section 509(a)(3) must
file Form 990 or Form 990-EZ even if their gross receipts are normally $50,000
or less. Supporting organizations of certain religious organizations need not file
Form 990 or Form 990-EZ if their gross receipts are normally $5,000 or less. These
organizations must, however, file the Form 990-N.
Supporting organizations must indicate whether they are a Type I, Type II or Type III
(and Functionally or Non-Functionally Integrated) supporting organization, identify
their supported organizations and annually certify that they are not directly or
indirectly controlled by a disqualified person. See the instructions for Schedule A
(Form 990 or Form 990-EZ), Public Charity Status and Public Support, and Notice
2006-109 to determine an organization’s appropriate supporting organization
type for information return purposes. For a brief overview of the requirements for
qualification as a supporting organization and the different types of supporting
organization, see Publication 557 and www.irs.gov/charities-non-profits.

Sponsoring organizations of donor advised funds (defined as organizations that
maintain one or more donor advised funds), and organizations that have controlled
entities must file Form 990, not Form 990-EZ, if required to file an annual
information return for the year.
Form 990 and Form 990-EZ
Form 990 consists of a core form and schedules. Each organization that files the
form must complete the entire core form. The core Form 990 includes a Summary
Page that provides a “snapshot” of the organization’s key financial and operating
information for the current and prior year.
All Form 990 filers will provide information about their program service
accomplishments, compensation of certain officers, directors and key employees
as well as information about governance practices and procedures and financial
information.
Each organization that files Form 990 must complete Part IV of Form 990,
Checklist of Required Schedules, to determine which schedules it must complete
based on its activities. See the instructions for Form 990-EZ for information about
which schedules 990-EZ filers must complete.
Schedule A, Public Charity Status and Public Support, and
Schedule B, Schedule of Contributors
Public charities that file Form 990 or Form 990-EZ must file Schedule A, Public
Charity Status and Public Support.
10
A new IRC Section 501(c)(3) organization will be classified as a public charity, and
not a private foundation, during its first five years if it can show when it applies for
tax-exempt status that it can reasonably expect to be publicly supported.
The IRS will monitor a new organization’s public charity status after the first five
years of existence based on the public support information reported annually by
the organization on Schedule A based on a five-year computation period that
includes the current year and the four prior years (including short years).
Beginning with the organization’s sixth year and for all succeeding years, if an
organization meets the public support test on Schedule A, the organization
qualifies as a public charity for its current year and the next tax year.
If a publicly supported charity fails the public support test for two consecutive
years, it will be reclassified as a private foundation.
See Publication 4220, Applying for 501(c)(3) Tax-Exempt Status, for details on the
distinctions between public charities and private foundations.
Most public charities that received contributions of $5,000 or more from any one
contributor must file Schedule B, Schedule of Contributors. See Part IV, line 2 of
Form 990 and the instructions to Schedule B (Form 990, 990-EZ) for complete
instructions.

Also, see www.irs.gov/charities-non-profits for additional information about other
schedules that a public charity may be required to complete based on the nature
of its activities.
Reporting Excess Benefit Transactions
If a public charity believes it provided an excess benefit to a person who is able
to exercise substantial influence over the organization’s affairs, it must report
the transaction on Form 990 or Form 990-EZ. Excess benefit transactions are
governed by IRC Section 4958. See Appendix G of the Form 990 Instructions for a
discussion of Section 4958, and Schedule L, Part I, regarding reporting of excess
benefit transactions.
Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt
Organizations Not Required To File Form 990 or 990-EZ
Any public charity that is not required to file Form 990 or 990-EZ because its
annual gross receipts are normally $50,000 or less must instead file Form 990-N,
Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required To File
Form 990 or Form 990-EZ. Exceptions to this requirement include organizations
that are included in a group return; churches, their integrated auxiliaries and
conventions or associations of churches; and organizations required to file a
different return.
The Form 990-N is due by the 15th day of the fifth month after the close of the
organization’s tax year. For example, if your organization’s tax year ends on
December 31, the Form 990-N is due May 15 of the following year. The e-Postcard
cannot be filed until the organization’s tax year ends.
The form must be completed and filed electronically. There is no paper form.
An organization is required to provide the following information on Form 990-N:
■■ legal name,
■■ any other names the organization uses,
■■ mailing address,
■■ website address (if applicable),
■■ employer identification number (EIN), also known as a taxpayer identification
number (TIN),
■■ name and address of a principal officer,
■■ annual tax year,
■■ confirmation that the organization’s annual gross receipts are $50,000 or less,
and
■■ if applicable, a statement that the organization has terminated or is terminating
(going out of business).
Read Filing Penalties and Revocation of Tax-Exempt Status below on the
consequences for failure to file this annual electronic notice
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FILING PENALTIES AND REVOCATION OF TAX-EXEMPT STATUS
If a Form 990 or Form 990-EZ is not filed, the IRS may assess penalties on the organization of $20 per
day until it is filed. This penalty also applies when the filer fails to include required information or to show
correct information. The penalty for failure to file a return or a complete return may not exceed the lesser of
$10,000 or 5 percent of the organization’s gross receipts. For an organization that has gross receipts of over
$1 million for the year, the penalty is $100 a day up to a maximum of $50,000. The IRS may impose penalties
on organization managers who do not comply with a written demand that the information be filed.
IRC Section 6033(j) provides that failure to file Form 990, Form 990-EZ or Form 990-N for three consecutive
years results in revocation of tax-exempt status as of the filing due date for the third return. An organization
whose exemption is revoked under this section must apply for reinstatement by filing a new application
and paying a user fee, whether or not the organization was originally required to file for exemption.
Reinstatement of exemption may be retroactive if the organization shows that the failure to file was for
reasonable cause.
E-Filing Requirements
Public charities with $10 million or more in total assets and that also file at least 250
returns in a calendar year (including income, excise, employment tax and information
returns such as Forms W-2 and 1099) must electronically file Form 990. Other public
charities are given a choice to file Form 990 electronically.
Form 990-T, Exempt Organization Business Income Tax Return
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A public charity must file a Form 990-T, Exempt Organization Business Income Tax
Return, if it has $1,000 or more of gross income from an unrelated trade or business
during the year. Net income from income-producing activities is taxable if the
activities:
■■ constitute a trade or business,
■■ are regularly carried on, and
■■ are not substantially related to the organization’s exempt purpose.
Examples of unrelated business income may include income from advertising in
publications, income from gaming (except for income from traditional bingo under
certain circumstances) and income from the sale of merchandise unrelated to the
organization’s exempt purpose. Whether an income-producing activity is an unrelated
trade or business activity depends on all the facts and circumstances. For more
information, see IRS Publication 598, Tax on Unrelated Business Income of Exempt
Organizations.
The public charity must pay quarterly estimated tax on unrelated business income
if it expects its tax for the year to be $500 or more. Form 990-W, Estimated Tax on
Unrelated Business Taxable Income for Tax-Exempt Organizations, is a worksheet to
determine the amount of estimated tax payments required.

FORM 990-T FILING PENALTIES
An organization may be subject to interest and penalty charges if it files a late return, fails to pay tax when
due, or fails to pay estimated tax, if required, even if it did not expect its tax for the year to be $500 or more.
Exceptions and Special Rules
Income from certain trade or business activities is excepted from the definition
of unrelated business income. Earnings from these sources are not subject to
the unrelated business income tax. Exceptions generally include business
income from:
■■ activities, including fundraisers, that are conducted by volunteer workers, or
where donated merchandise is sold;
■■ activities conducted by a charitable organization or by a governmental college
or university for the convenience of members, students, patients or employees;
■■ qualified conventions and trade shows;
■■ qualified sponsorship activities; and
■■ qualified bingo activities.
Income from investments and other “passive” activities is usually excluded from
the calculation of unrelated business taxable income. Examples of this type of
income include earnings from routine investments such as certificates of deposit,
savings accounts, or stock dividends; royalties; certain rents from real property;
and certain gains or losses from the sale of property.
13
Special rules apply to income derived from real estate or other investments
purchased with borrowed funds. This income is called “debt-financed” income.
Unrelated debt-financed income generally is subject to the unrelated business
income tax.
To learn about unrelated business income, see Publication 598, Form 990-T
instructions and Form 990-W instructions.
Employment Tax Returns
Like other employers, all public charities that pay wages to employees must withhold,
deposit and pay employment tax, including federal income tax withholding
and Social Security and Medicare (FICA) taxes. A public charity must withhold
federal income tax from employee wages and pay FICA on each employee paid
$100 or more in wages during a calendar year. To know how much income tax
to withhold, a public charity should have a Form W-4, Employee’s Withholding
Allowance Certificate, on file for each employee. Employment taxes are reported
on Form 941, Employer’s Quarterly Federal Tax Return.
If the IRS has instructed a small employer (one who has withheld employment taxes
of $1,000 or less during the year) to file Form 944, Employer’s Annual Federal Tax
Return, instead of Form 941, the employer must do so. The employer must file Form

944 even if there is no tax due or if the taxes exceed $1,000 unless the IRS tells it
to file Form 941 (or it is filing a final return). The instructions for Form 944 provides
information on how to have the filing requirement changed from Form 944 to Form
941.
Any person who fails to withhold and pay employment tax may be subject to
penalties. Public charities do not pay federal unemployment (FUTA) tax.
Public charities do not generally have to withhold or pay employment tax on
payments to independent contractors, but they may have information reporting
requirements. If a charity incorrectly classifies an employee as an independent
contractor, it may be held liable for employment taxes for that worker.
The requirements for withholding, depositing, reporting and paying employment
taxes are explained in Publication 15, (Circular E), Employer’s Tax Guide. For
help in determining if workers are employees or independent contractors, see
Publication 15-A, Employer’s Supplemental Tax Guide. Publication 557 covers
the employment tax responsibilities of public charities.
Employment Taxes and Churches
Although churches are excepted from filing Form 990, they do have employment
tax responsibilities. Employees of churches or church-controlled organizations are
subject to income tax withholding, but may be exempt from FICA taxes. Like other
501(c)(3) organizations, churches are not required to pay FUTA tax. In addition,
although ministers generally are common-law employees, they are not treated as
employees for employment tax purposes. These special employment tax rules
for members of the clergy and religious workers are explained in Publication 517,
Social Security and Other Information for Members of the Clergy and Religious
Workers. Churches also should consult Publications 15 and 15-A and Publication
1828, Tax Guide for Churches and Religious Organizations.
14
Why Keep Records?
In general, a public charity must maintain books and records to show that it complies
with tax rules. The charity must be able to document the sources of receipts
and expenditures reported on Form 990 or Form 990-EZ and Form 990-T. (See
Prepare Annual Information and Tax Returns on page 15.)
If an organization does not keep required records, it may not be able to show that it
qualifies for tax-exempt status or should be classified as a public charity. Thus, the
organization may lose its tax-exempt status or be classified as a private foundation
rather than a public charity. In addition, a public charity may be unable to complete
its returns accurately and, therefore, may be subject to penalties described under
Filing Penalties and Revocation of Tax-Exempt Status on page 12. When good
recordkeeping systems are in place, a public charity can evaluate the success of its
programs, monitor its budget and prepare its financial statements and returns.

Evaluate Charitable Programs
A charity can use records to evaluate the success of its charitable program and
determine whether the organization is achieving desired results. Good records
can also help a charity identify problem areas and determine what changes it may
need to make to improve performance.
Monitor Budgetary Results
Without proper financial records, it is difficult for a charity to assess whether it has
been successful in adhering to budgetary guidelines. The ability to monitor income
and expenses and ensure that the organization is operating within its budget is
crucial to successful stewardship of a public charity.
Prepare Financial Statements
It is important to maintain sufficient financial information to prepare accurate and
timely annual financial statements. A charity may need these statements when it is
working with banks, creditors, contributors and funding organizations. Some states
require charities to make audited financial statements publicly available.
Prepare Annual Information and Tax Returns
Records must support income, expenses and credits reported on Form 990 series
and other tax returns. Generally, these are the same records used to monitor programs
and prepare financial statements. Books and records of public charities
must be available for inspection by the IRS. If the IRS examines a public charity’s
returns, the organization must have records to explain items reported. Having a
complete set of records will speed up the examination.
15
Identify Sources of Receipts
Public charities may receive money or property from many sources. With thorough
recordkeeping, a charity can identify the sources of receipts. Organizations need
this information to separate program from non-program receipts, taxable from
non-taxable income and to complete Schedule A, as well as other schedules of the
Form 990 the organization may be required to complete, noted in What Federal
Information Returns, Tax Returns and Notices Must be Filed? on page 8. An
organization should maintain a list of its donors and grantors and the amount
of cash contributions or grants (or a description of the noncash contributions)
received from each.
Substantiate Revenues, Expenses and Deductions
for Unrelated Business Income Tax (UBIT) Purposes
An organization needs to keep records of revenues derived from, and expenses
attributable to, an unrelated trade or business so that it can properly prepare Form
990-T and calculate its unrelated business taxable income.

Comply with Grant-Making Procedures (Grants to Individuals)
A public charity that makes grants to individuals must keep adequate records and
case histories to demonstrate that the grants serve its charitable purposes. Case
histories on grants to individuals should show names, addresses, purposes of
grants, manner of selection and relationship (if any) that the recipient has with any
members, officers, trustees or donors of the organization. Schedule I of Form 990
and instructions provides more information about appropriate records required to
report on grants made within the United States. See also Schedule F of Form 990
for information about records required to report on foreign grants.
Comply with Racial Nondiscrimination Requirements (Private Schools)
Private schools must keep records that show they have complied with
requirements relating to racial nondiscrimination, including annual publication of
a racially nondiscriminatory policy through newspaper or broadcast media to the
general community served. For more information, see Schedule E of Form 990.
What Records Should be Kept?
Except in a few cases, the law does not require a special kind of record. A public
charity can choose any recordkeeping system, suited to its activities, that clearly
shows the organization’s income and expenses. The types of activities a public
charity conducts determines the type of records that should be kept for federal
tax purposes. A public charity should set up a recordkeeping system using an
accounting method that is appropriate for proper monitoring and reporting of its
financial activities for the tax year. If a public charity has more than one program,
it should ensure that the records appropriately identify the income and expense
items that are attributable to each program.
16
A recordkeeping system should generally include a summary of transactions. This
summary is ordinarily written in the public charity’s books (for example, accounting
journals and ledgers). The books must show gross receipts, purchases, expenses
(other than purchases), employment taxes and assets. For most small organizations,
the checkbook might be the main source for entries in the books while larger
organizations would need more sophisticated ledgers and records. A public charity
must keep documentation that supports entries in the books.

RECORDS MANAGEMENT
GROSS RECEIPTS,
Gross receipts are the amounts received from all sources, including contributions. A public charity should
keep supporting documents that show the amounts and sources of its gross receipts. Documents that show
gross receipts include: donor correspondence, pledge documents, cash register tapes, bank deposit slips,
receipt books, invoices, credit card charge slips and Forms 1099-MISC, Miscellaneous Income.
PURCHASES, INCLUDING ACCOUNTING FOR INVENTORY,
Purchases are items bought, including any items resold to customers. If an organization produces items,
it must account for any items resold to customers. Thus, for example, the organization must account for the
cost of all raw materials or parts purchased for manufacture into finished products. Supporting documents
should show the amount paid and that the amount was for purchases. Documents for purchases include:
canceled checks, cash register tape receipts, credit card sales slips and invoices. These records will help a
public charity determine the value of its inventory at the end of the year. See Publication 538, Accounting
Periods and Methods, for general information on methods for valuing inventory.
EXPENSES
Expenses are the costs a public charity incurs (other than purchases) to carry on its program. Supporting
documents should show the amount paid and the purpose of the expense. Documents for expenses include:
canceled checks, cash register tapes, contracts, account statements, credit card sales slips, invoices and
petty-cash slips for small cash payments.
EMPLOYMENT TAXES
Organizations that have employees must keep records of compensation and specific employment tax
records. See Publication 15, (Circular E), Employer’s Tax Guide, for details.
17
ASSETS & LIABILITIES
Assets are the property, such as investments, buildings and furniture that an organization owns and uses in
its activities. Liabilities reflect the financial obligations of the organization. A public charity must keep records
to verify certain information about its assets and liabilities. Records should show:
■ when and how the asset was acquired,
■ whether any debt was used to acquire the asset, ,
■ documents that support mortgages, notes,
loans or other forms of debt,
■ purchase price, ,
■ cost of any improvements,,
■ deductions taken for depreciation, if any ,,
■ deductions taken for casualty losses, if any, such
as losses resulting from fires or storms,
■ how the asset was used,
■ when and how the asset was disposed of,
■ selling price,
■ expenses of sale,
Documents that may show the above information include: purchase and sales invoices, real estate closing
statements, canceled checks and financing documents. If a public charity does not have canceled
checks, it may be able to show payment with certain financial account statements prepared by financial
institutions. These include account statements prepared for the financial institution by a third party.
All information, including account statements, must be highly legible. The following defines acceptable
account statements.
IF payment is by:
check
electronic funds
transfer
credit card
THEN statement must show:
check number, amount, payee’s name and date the check amount was posted to
the account by the financial institution
amount transferred, payee’s name and date the transfer was posted to the
account by the financial institution
amount charged, payee’s name and transaction date

Accounting Periods and Methods
A public charity must keep its books and records based on an annual accounting
period called a tax year to comply with annual reporting requirements.
Accounting Periods — A tax year is usually 12 consecutive months. There are two
kinds of tax years:
CALENDAR TAX YEAR – This is a period of 12 consecutive months beginning
January 1 and ending December 31.
FISCAL TAX YEAR – This is a period of 12 consecutive months ending on the last
day of any month except December.
Accounting Method — An accounting method is a set of rules used to determine
when and how income and expenses are reported. A public charity chooses
an accounting method when it files its first annual return. There are two basic
accounting methods:
CASH METHOD – Under the cash method, a public charity reports income in the
tax year received. It usually deducts expenses in the year paid.
ACCRUAL METHOD – Under an accrual method, a public charity generally records
income in the tax year earned (in other words, in the tax year in which a pledge is
received, even though it may receive payment in a later year). It records expenses
in the tax year incurred.
18
For more information about accounting periods and methods, see Publication 538,
Accounting Periods and Methods, and the instructions to Form 990 and Form 990-EZ.
Supporting Documents
Organization transactions such as contributions, purchases, sales and payroll
will generate supporting documents. These documents — grant applications
and awards, sales slips, paid bills, invoices, receipts, deposit slips and canceled
checks — contain information to be recorded in accounting records. It is important
to keep these documents because they support the entries in books and the
entries on tax and information returns. Public charities should keep supporting
documents organized by year and type of receipt or expense. Also, keep records
in a safe place.
How Long Should Records be Kept?
Public charities must keep records for federal tax purposes for as long as they
may be needed to document evidence of compliance with provisions of the IRC.
Generally, this means the organization must keep records that support an item of
income or deduction on a return until the statute of limitations for that return runs.
The statute of limitations has run when the organization can no longer amend
its return and the IRS can no longer assess additional tax. Generally, the statute

of limitations runs three years after the date the return is due or filed, whichever
is later. An organization may be required to retain records longer for other legal
purposes, including state or local tax purposes.
Record Retention Periods
Record retention periods vary depending on the types of records and returns.
Permanent Records – Some records should be kept permanently. These include
the application for recognition of tax-exempt status, the determination letter
recognizing tax-exempt status and organizing documents, such as articles of
incorporation and bylaws, with amendments, as well as board minutes.
Employment Tax Records – If an organization has employees, it must keep
employment tax records for at least four years after filing the fourth quarter for
the year.
Records for Non-Tax Purposes – When records are no longer needed for tax
purposes, an organization should keep them until they are no longer needed for
non-tax purposes. For example, a grantor, insurance company, creditor or state
agency may require that records be kept longer than the IRS requires.
What Governance Procedures and Practices Should
an Organization Consider Adopting or Have in Place?
19
While federal law doesn’t mandate any management structures, operational policies
or administrative practices, it’s important that public charities be thoughtful about
the governance practices that are most appropriate for that charity in assuring
sound operations and compliance with the tax law. While you may not be required
to have one policy or another, the IRS is authorized by Section 6033 to ask for
information we consider to be relevant to tax administration, including governance.
Mission Statement and Organizational Documents
The IRS encourages every charity to adopt, establish and regularly review a
mission statement to explain the organization’s purposes and guide its work.
Significant changes in your organizational documents should be reported to the
IRS, as noted below.
Governing Body
An active and engaged board is important to the success of a public charity and
compliance with the tax law. A governing board should be composed of persons
who are informed and active in overseeing a charity’s operations and finances. To
guard against insider transactions that could result in misuse of charitable assets,
the governing board should include independent members and should not be
dominated by employees or others who are not independent because of business
or family relationships.

Governance and Management Policies
Although the IRC does not require charities to have governance and management
policies, the IRS does encourage boards of charities to consider whether the
implementation of policies relating to executive compensation, conflicts of interest,
investments, fundraising, documentation of governance decisions, document
retention and whistleblower claims may be necessary and appropriate.
Further, if a public charity has chapters or affiliates, it is encouraged to have
procedures or policies in place to ensure consistency in operations.
Financial Statements and Information Reporting
Board members are encouraged to regularly review the organization’s financial
statements and information returns, and consider whether an independent auditor
is appropriate.
Transparency
Public charities are encouraged to adopt and monitor procedures to ensure that
information about their mission, activities, finance and governance is made publicly
available.
How Should Changes be Reported to the IRS?
20
Reporting Changes on the Annual Information Return
A public charity that is required to file Form 990 or Form 990-EZ must report name
and address changes, significant program changes and changes to its organizing
or enabling document or to its rules governing its affairs (commonly known as
bylaws) on its annual information return. For information about informing the IRS of
a termination or merger see Publication 4779, Facts About Terminating or Merging
Your Exempt Organization.
Determination Letters and Private Letter Ruling Requests
A public charity may request a copy of a lost exemption letter or an updated
exemption letter that reflects a name or address change from the IRS Exempt
Organizations (EO) Determinations office.
A public charity may file Form 8940, Request for Miscellaneous Determination
under Section 507, 509(a), 4940, 4942, 4945, and 6033 of the Internal Revenue
Code, to request a determination letter for an exemption from Form 990 filing
requirement, advance approval that a potential grant or contribution constitutes
an “unusual grant,” reclassification of foundation status and other miscellaneous
determinations.

If a public charity is unsure about whether a proposed change in its purposes or
activities is consistent with its status as an exempt organization or as a public
charity, it may want to request a private letter ruling.
The IRS Office of Chief Counsel issues private letter rulings on proposed
transactions and on completed transactions — if the request is submitted before
the return is filed for the year in which the transaction was completed. The IRS
generally does not issue rulings to public charities on any other completed
transactions. The IRS will issue letter rulings to public charities on matters involving
a public charity’s exempt status, its public charity status, as well as other matters
including issues under Sections 501 through 514, 4911, 4912, 4955, 4958, 6033,
6104 and 6115.
Consult www.irs.gov/charities-non-profits for the appropriate procedures
for preparing and submitting a request for a determination letter, replacement
exemption letter, a letter reflecting a new name and address or private letter ruling.
For general information about reporting changes, you may contact EO Customer
Accounts Services at 877-829-5500.
What Disclosures are Required?
There are several disclosure requirements for public charities. Detailed information
on federal tax law disclosure requirements for 501(c)(3) tax-exempt organizations
can be found in Publication 557.
21
Public Inspection of Annual Returns and Exemption Applications
A public charity must make the following documents available for public inspection
and copying upon request and without charge (except for a reasonable charge
for copying). The IRS also makes these documents available for public inspection
and copying. A public charity may place reasonable restrictions on the time, place
and manner of in-person inspection and copying, and may charge a reasonable
fee for providing copies. It can charge no more for the copies than the per page
rate the IRS charges for providing copies. The copy fees are listed in the Freedom
of Information Act (FOIA) fee schedule. Although the IRS charges no fee for the
first 100 pages, the organization can charge a fee for all copies. The organization
can also charge the actual postage costs it pays to provide copies. A tax-exempt
organization does not have to comply with individual requests for copies if it makes
the documents widely available. This can be done by posting the documents on a
readily accessible website.
For details on disclosure rules and procedures for public charities, see Life Cycle
of a Public Charity and the instructions to Forms 990 and 1023.
Because certain forms, by law, must be made publicly available by the IRS and the
filer, do not include any personal identifying information, such as Social Security
numbers not required by the IRS, on these forms.

Exemption Application – A public charity must make available for public
inspection its exemption application, Form 1023, Application for Recognition of
Exemption Under Section 501(c)(3) of the Internal Revenue Code, or Form 1023-EZ,
Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of
the Internal Revenue Code, along with:
■■ all documents submitted with Form 1023,
■■ all documents the IRS requires the organization to submit in support of its
application, and
■■ the exemption ruling letter issued by the IRS.
Annual Information Return – A public charity must make available for public
inspection its annual information return (Form 990 series) with schedules,
attachments and supporting documents filed with the IRS. However, a public
charity that files a Form 990 or Form 990-EZ does not have to disclose the names
and addresses of contributors listed on Schedule B. All other information, including
the amount of contributions, the description of noncash contributions and any
other information provided will be open to public inspection unless it clearly
identifies the contributor.
Note: If an organization files a copy of Form 990 or Form 990-EZ, and
attachments, with any state, it should not include its Schedule B in the
attachments for the state, unless a schedule of contributors is specifically required
by the state. States that do not require the information might inadvertently make
the schedule available for public inspection along with the rest of the Form 990 or
Form 990-EZ.
22
Certain information may be withheld from public inspection. A return must be
made available for a period of three years from the date the return is required to
be filed or is filed, whichever is later.
Form 990-T – A public charity must make Form 990-T available for three years
from the date the Form 990-T is required to be filed including any extension.
Schedules, attachments and supporting documents filed with Form 990-T that
do not relate to unrelated business income tax are not required to be made
available. Notice 2007-45 and Notice 2008-49 provide interim guidance on how
the returns are to be made public. See Form 4506-A for procedures the public
may use to request a 501(c)(3) organization’s Form 990-T from the IRS.
Public Inspection and Disclosure Procedures – A public charity may place
reasonable restrictions on the time, place and manner of in-person inspection and
copying, and may charge a reasonable fee for providing copies. It can charge no
more for the copies than the per page rate the IRS charges for providing copies.
A tax-exempt organization does not have to comply with individual requests for
copies if it makes the documents widely available. This can be done by posting the
documents on a readily accessible website.
All publicly-available information may be obtained from the IRS by using Form
4506-A, Request for Public Inspection or Copy of Exempt or Political Organization
IRS Form (a fee may apply). An organization may request a copy of its own return

on Form 4506-A. However, it will only receive the copy that is “Open for Public
Inspection.” An organization may request a complete copy of its own return by
completing Form 4506, Request for Copy of Tax Return, and paying the
applicable fee.
PENALTIES
Penalties apply to responsible persons of a tax-exempt organization who fail to provide the documents as
required. A penalty of $20 per day may apply for as long as the failure continues. A $10,000 maximum
penalty applies to a failure to provide an information return; no maximum penalty applies to application
requests.
Sale of Free Government Information
If a public charity offers to sell, or solicits money for, specific information or a
routine service that is available free from the federal government, the organization
must make an express statement at the time of solicitation about the free service.
An organization that intentionally disregards this requirement is subject to a penalty.
Charitable Contributions—Substantiation and Disclosure
A public charity should be aware of the substantiation and recordkeeping rules
imposed on donors who intend to claim a charitable contribution deduction and the
disclosure rules imposed on charities that receive certain quid pro quo contributions.
Recordkeeping Rules
23
A donor cannot claim a tax deduction for any cash, check or other monetary
contribution unless the donor maintains a record of the contribution in the form of
either a bank record (such as a cancelled check) or a written communication from
the charity (such as a receipt or a letter) showing the name of the charity, date and
amount of the contribution.
Substantiation Rules
A donor cannot claim a tax deduction for any single contribution of $250 or more
unless the donor obtains a contemporaneous written acknowledgment of the
contribution from the recipient public charity. A public charity may assist the donor by
providing a timely written statement including the name of the public charity, date and
amount of any cash contribution and description of any noncash contributions.
In addition, the acknowledgment should indicate whether any goods or services
were provided in return for the contribution. If any goods or services were provided
in return for a contribution, the organization should provide a description and good
faith estimate of the value of the goods or services.
The public charity may either provide separate acknowledgments for each single
contribution of $250 or more or one acknowledgment to substantiate several single
contributions of $250 or more. Separate contributions are not aggregated for
purposes of measuring the $250 threshold.
There are no IRS forms for the acknowledgment. Letters, postcards or computergenerated
forms with the above information are acceptable. An organization

can provide either a paper copy of the acknowledgment or an electronic
acknowledgment, such as an email, to the donor.
Disclosure Rules That Apply to Quid Pro Quo Contributions
Contributions are deductible only to the extent that they are gifts and no
consideration is received in return. Depending on the circumstances, ticket
purchases and similar payments made in conjunction with fundraising events
may not qualify as charitable contributions in full. A contribution made by a donor
in exchange for goods or services is known as a quid pro quo contribution. A
donor may only take a charitable contribution deduction to the extent that the
contribution exceeds the fair market value of the goods and services the donor
receives in return for the contribution.
If a public charity conducts fundraising events such as benefit dinners, shows and
membership drives, where something of value is given to those in attendance,
it must provide a written statement informing donors of the fair market value of
the specific items or services it provided in exchange for contributions. Token
items and services of intangible religious value need not be considered. A public
charity should provide the written disclosure statement in advance of any event,
determine the fair market value of any benefit received and state this information
in fundraising materials such as solicitations, tickets and receipts. The disclosure
statement should be made, at the latest, at the time payment is received. Subject
to certain exceptions, the disclosure responsibility applies to any fundraising
circumstance where each complete payment, including the contribution portion,
exceeds $75.
24
Publication 1771, Charitable Contributions—Substantiation and Disclosure
Requirements, and Publication 526, Charitable Contributions, provide details on
the federal tax law for organizations such as public charities, including churches,

How Do You Get IRS Assistance and Information?
The IRS offers help that is accessible online, via mail, by telephone and at IRS walkin
offices in many areas across the country. IRS forms and publications can be
downloaded from the internet and ordered by telephone.
Specialized Assistance for Tax-Exempt Organizations
Get help with questions about applying for tax-exempt status, annual filing
requirements and information about exempt organizations from the IRS Exempt
Organizations (EO) pages on the IRS website.
EO Website
www.irs.gov/charities-non-profits
Highlights:
■■ The Life Cycle of a Public Charity describes the compliance obligations of
charities.
■■ Subscribe to the EO Update, an electronic newsletter with information for taxexempt
organizations and tax practitioners who represent them.
EO Web-based Training
www.stayexempt.irs.gov
EO Customer Account Services 877-829-5500
25
EO Determinations Office Mailing Address
Internal Revenue Service,
TE/GE, EO Determinations Office,
Room 4024
P.O. Box 2508,
Cincinnati, OH 45201,

Tax Publications for Exempt Organizations
Get publications via the internet or by calling the IRS at 800-829-3676.
Pub 1, Your Rights as a Taxpayer,
Pub 15, (Circular E), Employer’s Tax Guide,
Pub 15-A, Employer’s Supplemental Tax Guide,
Pub 463, Travel, Entertainment, Gift, and Car Expenses,
Pub 517, Social Security and Other Information for Members of the Clergy
and Religious Workers,
Pub 526, Charitable Contributions,
Pub 538, Accounting Periods and Methods,
Pub 557, Tax-Exempt Status for Your Organization,
Pub 571, Tax-Sheltered Annuity Plans (403(b) Plans) for Employees of Public
Schools and Certain Tax-Exempt Organizations,
Pub 583, Starting a Business and Keeping Records,
Pub 598, Tax on Unrelated Business Income of Exempt Organizations,
Pub 1771, Charitable Contributions—Substantiation and Disclosure Requirements,
Pub 1828, Tax Guide for Churches and Religious Organizations,
Pub 3079, Tax-Exempt Organizations and Gaming,
26
Pub 3833, Disaster Relief, Providing Assistance Through Charitable Organizations,
Pub 4220, Applying for 501(c)(3) Tax-Exempt Status,
Pub 4221-NC, Compliance Guide for Tax-Exempt Organizations (other than 501(c)(3)
Public Charities and Private Foundations),
Pub 4221-PF, Compliance Guide for 501(c)(3) Private Foundations,
Pub 4302, A Charity’s Guide to Vehicle Donation,
Pub 4303, A Donor’s Guide to Vehicle Donation,
Pub 4630, The Exempt Organizations Products and Services Catalog,
Pub 4779, Facts about Terminating or Merging Your Exempt Organization,
Forms for Exempt Organizations
Form 941, Employer’s Quarterly Federal Tax Return,
Form 944, Employer’s Annual Federal Tax Return,
Form 990, Return of Organization Exempt From Income Tax,
Form 990-EZ, Short Form Return of Organization Exempt From Income Tax,
Form 990-PF, Return of Private Foundation or Section 4947(a)(1) Trust Treated as
Private Foundation,

Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not
Required to File Form 990 or 990-EZ (available electronically only),
Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax
under section 6033(e)),
Form 990-W, Estimated Tax on Unrelated Business Taxable Income for
Tax-Exempt Organizations (and on Investment Income for Private Foundations),
Form 1023, Application for Recognition of Exemption Under Section 501(c)(3)
of the Internal Revenue Code,
Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section
501(c)(3) of the Internal Revenue Code (available electronically only)
Form 1024, Application for Recognition of Exemption Under Section 501(a),
Form 1041, U.S. Income Tax Return for Estates and Trusts,
Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the
Internal Revenue Code,
Form 5578, Annual Certification of Racial Nondiscrimination for a Private School
Exempt From Federal Income Tax,
Form 5768, Election/Revocation of Election by an Eligible Section 501(c)(3)
Organization To Make Expenditures To Influence Legislation,
Form 8282, Donee Information Return (Sale, Exchange, or Other Disposition of
Donated Property)
27
Form 8283, Noncash Charitable Contributions,
Form 8868, Application for Automatic Extension of Time To File an Exempt
Organization Return,
FinCEN Form 114, Report of Foreign Bank and Financial Accounts,
General IRS Assistance
Get materials on the latest tax laws, assistance with forms and publications, and
filing information.
IRS Website,
www.irs.gov
Federal tax questions, 800-829-4933
Employment tax questions, 800-829-4933
Order IRS forms and publications, 800-829-3676
Publication 4221-PC (Rev. 3-2018) Catalog Number 49829R,,Department of the Treasury Internal Revenue Service, www.irs.gov,

Page 60 of 89

Attachment B
Quick Short-Term Impact Analysis
(2-2018)
Page 61 of 89

Quick Short-Term Impact Analysis
E-B Program Cost 1
$328,769.85 ÷ 600 kids = $547.95/ youth
÷ 12 mos. = $46./mo./youth
Family Spending per Youth $4,931,547.75 ÷ 8,219.25/kid 1 ÷ 600 kids =
not incarcerated (ROI) 2
÷ 12 mos. = $137./mo./youth
Spending per youth not incarcerated = $137./month/youth
Cost of Program(s) per youth not incarcerated = - $ 46./month/youth
$ 91./month/youth
Short-Term Benefit to Society = $ 91./month/youth x 600 kids x 60 mos. = $3,276,000.00 3
Annual Confinement Costs:
Pennsylvania
Not Reported
New Jersey $196,133.00 per youth (x 600 youth = $117,679,800)
Georgia $91,126.00 per youth (x 600 youth = $54,675,600)
Delaware
Not Reported
Washington DC $277,765.00 per youth (x 600 youth = $166,659,000)
5-Year Social Impact 4
New Jersey $117,679,800/year x 5 years = $588,399,000 + $3,276,000 = $591,675,000
Georgia $54,675,600/year x 5 years = $273,378,000 + $3,276,000 = $276,654,000
Wash DC $166,659,000/year x 5 years = $833,295,000 + $3,276,000 = $836,571,000
1
5-Year Analysis (2007 – 2011).
2
$15/$1 ROI Multiplier (per p. 110).
3
Slightly under a 10/1 ROI.
4
600 youth

Quick Short-Term Impact Analysis
E-B Program Cost 2
$328,769.85 ÷ 600 kids = $547.95/ youth
÷ 12 mos. = $46./mo./youth
Family Spending per Youth $4,931,547.75 ÷ 8,219.25/kid 1 ÷ 600 kids =
not incarcerated (ROI) 3
÷ 12 mos. = $137./mo./youth
Spending per youth not incarcerated = $137./month/youth
Cost of Program(s) per youth not incarcerated = - $ 46./month/youth
$ 91./month/youth
Short-Term Benefit to Society = $ 91./month/youth x 600 kids x 60 mos. = $3,276,000.00 4
Annual Confinement Costs:
Pennsylvania
Not Reported
New Jersey $196,133.00 per youth (x 600 youth = $117,679,800)
Georgia $91,126.00 per youth (x 600 youth = $54,675,600)
Delaware
Not Reported
Washington DC $277,765.00 per youth (x 600 youth = $166,659,000)
5-Year Social Impact 5
New Jersey $117,679,800/year x 5 years = $588,399,000 + $3,276,000 = $591,675,000
Georgia $54,675,600/year x 5 years = $273,378,000 + $3,276,000 = $276,654,000
Wash DC $166,659,000/year x 5 years = $833,295,000 + $3,276,000 = $836,571,000
2 5-Year Analysis (2007 – 2011).
3 $15/$1 ROI Multiplier (per p. 110).
4 Slightly under a 10/1 ROI.
5 600 youth
Page 62 of 89

Attachment C
EDTC Incubator Workshop Budget
Page 63 of 89

EDTC Incubator Workshop Budget
Assume: 15 participants and 2 leaders
All costs are Variable.
Description / Costs Workshop Per person
Program Coordinator: 1staff at
$40 per hr x 8 hours
Workshop Leaders: 1 staff
leader @ $40 per hr. x 3 hrs. x 6
sessions^ ; 1 community leader
@ $200 per workshop
Critical Thinking Books: 15
participants x $19/book
$320 $21
$920 $61.33
$285 $19
Flip Charts for Workshop: 2
per workshop @ $30
Miscellaneous Supplies: name
tags, pens, markers, note pads
Miscellaneous Copying: 5
pages x $.10 per page x 15
people
Snacks: $1.50 per person x 17
people x 6 days
$60 $4
$15 $2.50
$7.50 .50
$153 $9
Mileage for Leaders: 100 miles
x 6 days x 1 people x $.56 per
mile
$336 $22
Total Cost Per Workshop* $2,096.50 $140
Includes planning and preparation time plus administrative for copying, form
processing, etc.
Total cost $140 per person, plus cost of room rental (if any)
Page 64 of 89

Advocacy Foundation Publishers
Page 65 of 89

Advocacy Foundation Publishers
The e-Advocate Quarterly
Page 66 of 89

Issue Title Quarterly
Vol. I 2015 The Fundamentals
I
The ComeUnity ReEngineering
Project Initiative
Q-1 2015
II The Adolescent Law Group Q-2 2015
III
Landmark Cases in US
Juvenile Justice (PA)
Q-3 2015
IV The First Amendment Project Q-4 2015
Vol. II 2016 Strategic Development
V The Fourth Amendment Project Q-1 2016
VI
Landmark Cases in US
Juvenile Justice (NJ)
Q-2 2016
VII Youth Court Q-3 2016
VIII
The Economic Consequences of Legal
Decision-Making
Q-4 2016
Vol. III 2017 Sustainability
IX The Sixth Amendment Project Q-1 2017
X
The Theological Foundations of
US Law & Government
Q-2 2017
XI The Eighth Amendment Project Q-3 2017
XII
The EB-5 Investor
Immigration Project*
Q-4 2017
Vol. IV 2018 Collaboration
XIII Strategic Planning Q-1 2018
XIV
The Juvenile Justice
Legislative Reform Initiative
Q-2 2018
XV The Advocacy Foundation Coalition Q-3 2018
Page 67 of 89

XVI
for Drug-Free Communities
Landmark Cases in US
Juvenile Justice (GA)
Q-4 2018
Page 68 of 89

Issue Title Quarterly
Vol. V 2019 Organizational Development
XVII The Board of Directors Q-1 2019
XVIII The Inner Circle Q-2 2019
XIX Staff & Management Q-3 2019
XX Succession Planning Q-4 2019
XXI The Budget* Bonus #1
XXII Data-Driven Resource Allocation* Bonus #2
Vol. VI 2020 Missions
XXIII Critical Thinking Q-1 2020
XXIV
The Advocacy Foundation
Endowments Initiative Project
Q-2 2020
XXV International Labor Relations Q-3 2020
XXVI Immigration Q-4 2020
Vol. VII 2021 Community Engagement
XXVII
The 21 st Century Charter Schools
Initiative
Q-1 2021
XXVIII The All-Sports Ministry @ ... Q-2 2021
XXIX Lobbying for Nonprofits Q-3 2021
XXX
XXXI
Advocacy Foundation Missions -
Domestic
Advocacy Foundation Missions -
International
Q-4 2021
Bonus
Page 69 of 89

Vol. VIII
2022 ComeUnity ReEngineering
XXXII
The Creative & Fine Arts Ministry
@ The Foundation
Q-1 2022
XXXIII The Advisory Council & Committees Q-2 2022
XXXIV
The Theological Origins
of Contemporary Judicial Process
Q-3 2022
XXXV The Second Chance Ministry @ ... Q-4 2022
Vol. IX 2023 Legal Reformation
XXXVI The Fifth Amendment Project Q-1 2023
XXXVII The Judicial Re-Engineering Initiative Q-2 2023
XXXVIII
The Inner-Cities Strategic
Revitalization Initiative
Q-3 2023
XXXVIX Habeas Corpus Q-4 2023
Vol. X 2024 ComeUnity Development
XXXVX
The Inner-City Strategic
Revitalization Plan
Q-1 2024
XXXVXI The Mentoring Initiative Q-2 2024
XXXVXII The Violence Prevention Framework Q-3 2024
XXXVXIII The Fatherhood Initiative Q-4 2024
Vol. XI 2025 Public Interest
XXXVXIV Public Interest Law Q-1 2025
L (50) Spiritual Resource Development Q-2 2025
Page 70 of 89

LI
Nonprofit Confidentiality
In The Age of Big Data
Q-3 2025
LII Interpreting The Facts Q-4 2025
Vol. XII 2026 Poverty In America
LIII
American Poverty
In The New Millennium
Q-1 2026
LIV Outcome-Based Thinking Q-2 2026
LV Transformational Social Leadership Q-3 2026
LVI The Cycle of Poverty Q-4 2026
Vol. XIII 2027 Raising Awareness
LVII ReEngineering Juvenile Justice Q-1 2027
LVIII Corporations Q-2 2027
LVIX The Prison Industrial Complex Q-3 2027
LX Restoration of Rights Q-4 2027
Vol. XIV 2028 Culturally Relevant Programming
LXI Community Culture Q-1 2028
LXII Corporate Culture Q-2 2028
LXIII Strategic Cultural Planning Q-3 2028
LXIV
The Cross-Sector/ Coordinated
Service Approach to Delinquency
Prevention
Q-4 2028
Page 71 of 89

Vol. XV 2029 Inner-Cities Revitalization
LXIV
LXV
LXVI
Part I – Strategic Housing
Revitalization
(The Twenty Percent Profit Margin)
Part II – Jobs Training, Educational
Redevelopment
and Economic Empowerment
Part III - Financial Literacy
and Sustainability
Q-1 2029
Q-2 2029
Q-3 2029
LXVII Part IV – Solutions for Homelessness Q-4 2029
LXVIII
The Strategic Home Mortgage
Initiative
Bonus
Vol. XVI 2030 Sustainability
LXVIII Social Program Sustainability Q-1 2030
LXIX
The Advocacy Foundation
Endowments Initiative
Q-2 2030
LXX Capital Gains Q-3 2030
LXXI Sustainability Investments Q-4 2030
Vol. XVII 2031 The Justice Series
LXXII Distributive Justice Q-1 2031
LXXIII Retributive Justice Q-2 2031
LXXIV Procedural Justice Q-3 2031
LXXV (75) Restorative Justice Q-4 2031
LXXVI Unjust Legal Reasoning Bonus
Page 72 of 89

Vol. XVIII 2032 Public Policy
LXXVII Public Interest Law Q-1 2032
LXXVIII Reforming Public Policy Q-2 2032
LXXVIX ... Q-3 2032
LXXVX ... Q-4 2032
Page 73 of 89

The e-Advocate Monthly Review
2018
Transformational Problem Solving January 2018
The Advocacy Foundation February 2018
Opioid Initiative
Native-American Youth March 2018
In the Juvenile Justice System
Barriers to Reducing Confinement April 2018
Latino and Hispanic Youth May 2018
In the Juvenile Justice System
Social Entrepreneurship June 2018
The Economic Consequences of
Homelessness in America S.Ed – June 2018
African-American Youth July 2018
In the Juvenile Justice System
Gang Deconstruction August 2018
Social Impact Investing September 2018
Opportunity Youth: October 2018
Disenfranchised Young People
The Economic Impact of Social November 2018
of Social Programs Development
Gun Control December 2018
2019
The U.S. Stock Market January 2019
Prison-Based Gerrymandering February 2019
Literacy-Based Prison Construction March 2019
Children of Incarcerated Parents April 2019
Page 74 of 89

African-American Youth in The May 2019
Juvenile Justice System
Racial Profiling June 2019
Mass Collaboration July 2019
Concentrated Poverty August 2019
De-Industrialization September 2019
Overcoming Dyslexia October 2019
Overcoming Attention Deficit November 2019
The Gift of Adversity December 2019
2020
The Gift of Hypersensitivity January 2020
The Gift of Introspection February 2020
The Gift of Introversion March 2020
The Gift of Spirituality April 2020
The Gift of Transformation May 2020
Property Acquisition for
Organizational Sustainability June 2020
Investing for Organizational
Sustainability July 2020
Biblical Law & Justice TLFA August 2020
Gentrification AF September 2020
Environmental Racism EDTC October 2020
Law for The Poor AF November 2020
…
Page 75 of 89

2021
Biblically Responsible Investing TLFA – January 2021
International Criminal Procedure LMI – February 2021
Spiritual Rights TLFA – March 2021
The Theology of Missions TLFA – April 2021
Legal Evangelism, Intelligence,
Reconnaissance & Missions LMI – May 2021
The Law of War LMI – June 2021
Generational Progression AF – July 2021
…
Page 76 of 89

The e-Advocate Quarterly
Special Editions
Crowdfunding Winter-Spring 2017
Social Media for Nonprofits October 2017
Mass Media for Nonprofits November 2017
The Opioid Crisis in America: January 2018
Issues in Pain Management
The Opioid Crisis in America: February 2018
The Drug Culture in the U.S.
The Opioid Crisis in America: March 2018
Drug Abuse Among Veterans
The Opioid Crisis in America: April 2018
Drug Abuse Among America’s
Teens
The Opioid Crisis in America: May 2018
Alcoholism
The Economic Consequences of June 2018
Homelessness in The US
The Economic Consequences of July 2018
Opioid Addiction in America
Page 77 of 89

The e-Advocate Journal
of Theological Jurisprudence
Vol. I - 2017
The Theological Origins of Contemporary Judicial Process
Scriptural Application to The Model Criminal Code
Scriptural Application for Tort Reform
Scriptural Application to Juvenile Justice Reformation
Vol. II - 2018
Scriptural Application for The Canons of Ethics
Scriptural Application to Contracts Reform
& The Uniform Commercial Code
Scriptural Application to The Law of Property
Scriptural Application to The Law of Evidence
Page 78 of 89

Legal Missions International
Page 79 of 89

Issue Title Quarterly
Vol. I 2015
I
II
God’s Will and The 21 st Century
Democratic Process
The Community
Engagement Strategy
Q-1 2015
Q-2 2015
III Foreign Policy Q-3 2015
IV
Public Interest Law
in The New Millennium
Q-4 2015
Vol. II 2016
V Ethiopia Q-1 2016
VI Zimbabwe Q-2 2016
VII Jamaica Q-3 2016
VIII Brazil Q-4 2016
Vol. III 2017
IX India Q-1 2017
X Suriname Q-2 2017
XI The Caribbean Q-3 2017
XII United States/ Estados Unidos Q-4 2017
Vol. IV 2018
XIII Cuba Q-1 2018
XIV Guinea Q-2 2018
XV Indonesia Q-3 2018
XVI Sri Lanka Q-4 2018
Page 80 of 89

Vol. V 2019
XVII Russia Q-1 2019
XVIII Australia Q-2 2019
XIV South Korea Q-3 2019
XV Puerto Rico Q-4 2019
Issue Title Quarterly
Vol. VI 2020
XVI Trinidad & Tobago Q-1 2020
XVII Egypt Q-2 2020
XVIII Sierra Leone Q-3 2020
XIX South Africa Q-4 2020
XX Israel Bonus
Vol. VII 2021
XXI Haiti Q-1 2021
XXII Peru Q-2 2021
XXIII Costa Rica Q-3 2021
XXIV China Q-4 2021
XXV Japan Bonus
Vol VIII 2022
XXVI Chile Q-1 2022
Page 81 of 89

The e-Advocate Juvenile Justice Report
______
Vol. I – Juvenile Delinquency in The US
Vol. II. – The Prison Industrial Complex
Vol. III – Restorative/ Transformative Justice
Vol. IV – The Sixth Amendment Right to The Effective Assistance of Counsel
Vol. V – The Theological Foundations of Juvenile Justice
Vol. VI – Collaborating to Eradicate Juvenile Delinquency
Page 82 of 89

The e-Advocate Newsletter
Genesis of The Problem
Family Structure
Societal Influences
Evidence-Based Programming
Strengthening Assets v. Eliminating Deficits
2012 - Juvenile Delinquency in The US
Introduction/Ideology/Key Values
Philosophy/Application & Practice
Expungement & Pardons
Pardons & Clemency
Examples/Best Practices
2013 - Restorative Justice in The US
2014 - The Prison Industrial Complex
25% of the World's Inmates Are In the US
The Economics of Prison Enterprise
The Federal Bureau of Prisons
The After-Effects of Incarceration/Individual/Societal
The Fourth Amendment Project
The Sixth Amendment Project
The Eighth Amendment Project
The Adolescent Law Group
2015 - US Constitutional Issues In The New Millennium
Page 83 of 89

2018 - The Theological Law Firm Academy
The Theological Foundations of US Law & Government
The Economic Consequences of Legal Decision-Making
The Juvenile Justice Legislative Reform Initiative
The EB-5 International Investors Initiative
2017 - Organizational Development
The Board of Directors
The Inner Circle
Staff & Management
Succession Planning
Bonus #1 The Budget
Bonus #2 Data-Driven Resource Allocation
2018 - Sustainability
The Data-Driven Resource Allocation Process
The Quality Assurance Initiative
The Advocacy Foundation Endowments Initiative
The Community Engagement Strategy
2019 - Collaboration
Critical Thinking for Transformative Justice
International Labor Relations
Immigration
God's Will & The 21st Century Democratic Process
The Community Engagement Strategy
The 21st Century Charter Schools Initiative
2020 - Community Engagement
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Extras
The Nonprofit Advisors Group Newsletters
The 501(c)(3) Acquisition Process
The Board of Directors
The Gladiator Mentality
Strategic Planning
Fundraising
501(c)(3) Reinstatements
The Collaborative US/ International Newsletters
How You Think Is Everything
The Reciprocal Nature of Business Relationships
Accelerate Your Professional Development
The Competitive Nature of Grant Writing
Assessing The Risks
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About The Author
John C (Jack) Johnson III
Founder & CEO
Jack was educated at Temple University, in Philadelphia, Pennsylvania and Rutgers
Law School, in Camden, New Jersey. In 1999, he moved to Atlanta, Georgia to pursue
greater opportunities to provide Advocacy and Preventive Programmatic services for atrisk/
at-promise young persons, their families, and Justice Professionals embedded in the
Juvenile Justice process in order to help facilitate its transcendence into the 21 st Century.
There, along with a small group of community and faith-based professionals, “The Advocacy Foundation, Inc." was conceived
and developed over roughly a thirteen year period, originally chartered as a Juvenile Delinquency Prevention and Educational
Support Services organization consisting of Mentoring, Tutoring, Counseling, Character Development, Community Change
Management, Practitioner Re-Education & Training, and a host of related components.
The Foundation’s Overarching Mission is “To help Individuals, Organizations, & Communities Achieve Their Full Potential”, by
implementing a wide array of evidence-based proactive multi-disciplinary "Restorative & Transformative Justice" programs &
projects currently throughout the northeast, southeast, and western international-waters regions, providing prevention and support
services to at-risk/ at-promise youth, to young adults, to their families, and to Social Service, Justice and Mental
Health professionals” everywhere. The Foundation has since relocated its headquarters to Philadelphia, Pennsylvania, and been
expanded to include a three-tier mission.
In addition to his work with the Foundation, Jack also served as an Adjunct Professor of Law & Business at National-Louis
University of Atlanta (where he taught Political Science, Business & Legal Ethics, Labor & Employment Relations, and Critical
Thinking courses to undergraduate and graduate level students). Jack has also served as Board President for a host of wellestablished
and up & coming nonprofit organizations throughout the region, including “Visions Unlimited Community
Development Systems, Inc.”, a multi-million dollar, award-winning, Violence Prevention and Gang Intervention Social Service
organization in Atlanta, as well as Vice-Chair of the Georgia/ Metropolitan Atlanta Violence Prevention Partnership, a state-wide
300 organizational member, violence prevention group led by the Morehouse School of Medicine, Emory University and The
Original, Atlanta-Based, Martin Luther King Center.
Attorney Johnson’s prior accomplishments include a wide-array of Professional Legal practice areas, including Private Firm,
Corporate and Government postings, just about all of which yielded significant professional awards & accolades, the history and
chronology of which are available for review online. Throughout his career, Jack has served a wide variety of for-profit
corporations, law firms, and nonprofit organizations as Board Chairman, Secretary, Associate, and General Counsel since 1990.
www.TheAdvocacyFoundation.org
Clayton County Youth Services Partnership, Inc. – Chair; Georgia Violence Prevention Partnership, Inc – Vice Chair; Fayette
County NAACP - Legal Redress Committee Chairman; Clayton County Fatherhood Initiative Partnership – Principal
Investigator; Morehouse School of Medicine School of Community Health Feasibility Study - Steering Committee; Atlanta
Violence Prevention Capacity Building Project – Project Partner; Clayton County Minister’s Conference, President 2006-2007;
Liberty In Life Ministries, Inc. – Board Secretary; Young Adults Talk, Inc. – Board of Directors; ROYAL, Inc - Board of
Directors; Temple University Alumni Association; Rutgers Law School Alumni Association; Sertoma International; Our
Common Welfare Board of Directors – President)2003-2005; River’s Edge Elementary School PTA (Co-President); Summerhill
Community Ministries; Outstanding Young Men of America; Employee of the Year; Academic All-American - Basketball;
Church Trustee.
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www.TheAdvocacyFoundation.org
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