The Higher Synthesis Foundation is a private non-operating charity with full 501(c)(3) status, registered under the name of Aufhebung Foundation. It is managed by Foundation Source. The charitable activity of the Higher Synthesis Foundation is research with benefit for the public.
Private non-operating foundations must follow Expenditure Responsibility procedures to receive grants.
Expenditure Responsibility is the federally-mandated procedure that a private non-operating foundation must follow for any grant made to an organization that is not an IRS-recognized public charity. The grantor foundation is required by law to impose additional requirements on the grantee to provide assurance that the funds will be used for the intended charitable purposes. Expenditure Responsibility, therefore, is necessary in connection with grants to any entity structured in nature as follows:
- Non-501(c)(3) tax-exempt organizations (civic associations, veterans groups, business leagues, etc.)
- Private non-operating foundations (there is an extra requirement if the granting foundation expects the grant to count towards satisfying its own 5% minimum distribution requirement)
- Private operating foundations (the same additional requirement applicable to grants made to non-operating foundations applies here)
- For-profit companies
- Foreign (international) organizations (there is an alternate approach to foreign organizations in lieu of Expenditure Responsibility)
Keep in mind, no matter who or what the grantee may be, the purpose of the grant must be to accomplish a charitable purpose that will benefit the public at large. Expenditure responsibility grants may never be for unrestricted (“general operating support”) but must always have a specific charitable purpose. The process itself involves a grant application, a special grant agreement (prepared by a qualified advisor, such as an attorney) and a follow up report to the grantor foundation, all with appropriate documentation attached.
For further information, please look at the following documents:
- Expenditure Responsibility: A Primer by Rosemary E. Fei, January 2008 (a general statement of the Federal tax law concerning expenditure)
- Comparing Public Charities and Private Foundations (a Foundation Source information document).
You may also contact the manager of the Higher Synthesis Foundation at Foundation Source: Ryan DeMaria <rdemaria at foundationsource.com>.