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  • 1.  Disclosure of Complimentary Tickets?

    Posted 06-13-2023 05:02 PM

    Does anyone provide disclosure of gifts or benefits given to someone in case they are a Form 700 filer? If so, could you share what your policies and best practices are for adhering to the disclosure, especially if you're unaware if they are a Form 700 filer?

    For example, if someone received benefits of complimentary tickets to 1+ event(s) and had a meal within 1 calendar year and the amount may or may not meet the threshold for maximum benefit amount to be reported for Form 700, do you provide an annual written disclosure of benefits received?

    Thank you!
    Aimee



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    Aimee Holland
    Alameda Health System Foundation
    aholland@alamedahealthsystem.org
    ------------------------------


  • 2.  RE: Disclosure of Complimentary Tickets?

    Posted 06-13-2023 05:11 PM
    The filing of a 700 is irrelevant. The substantiation regulations, as outlined in IRS Publication 1771, pertain to anyone. You must still disclose all benefits that exceed the annual minimum threshold established by the IRS. Whether the donor utilizes that information when completing the 700 is their prerogative (and legal responsibility).

    John

    John H. Taylor
    Principal
    John H. Taylor Consulting, LLC
    2604 Sevier St.
    Durham, NC   27705
    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987






  • 3.  RE: Disclosure of Complimentary Tickets?

    Posted 06-14-2023 08:44 AM

    Hi John,

    In this case, the person who may receive the complimentary ticket is a prospective donor who has not given nor is obligated to. Are there substantiation regulations that require the disclosure of the benefits and the value of those benefits received when someone is not a donor?



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    Aimee Holland
    Alameda Health System Foundation
    aholland@alamedahealthsystem.org
    ------------------------------



  • 4.  RE: Disclosure of Complimentary Tickets?

    Posted 06-14-2023 08:54 AM
    No. The IRS donation regulations pertain only to donors who receive, or expect to receive, benefits in exchange for a contribution. You don't need to disclose anything on a gift receipt if anyone can receive a benefit without making a gift.

    But those are charitable donation regulations. I am unfamiliar with California State laws regarding benefits of any sort provided to political figures regardless of a contribution. That would be something to discuss with counsel.

    John

    John H. Taylor
    Principal
    John H. Taylor Consulting, LLC
    2604 Sevier St.
    Durham, NC   27705
    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987







  • 5.  RE: Disclosure of Complimentary Tickets?

    Posted 06-14-2023 09:11 AM

    Thank you so much! We'll definitely take that next step.

    Cheers,

    Aimee



    ------------------------------
    Aimee Holland
    Alameda Health System Foundation
    aholland@alamedahealthsystem.org
    ------------------------------