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To Satisfy the Broadly Supported Provision to Avoid Classification as a Private

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To satisfy the broadly supported provision to avoid classification as a private foundation, the exempt organization must satisfy both an external support test and an internal support test. Under the internal support test, more than one- third of the exempt organization's support for the taxable year must come from gross investment income and unrelated business taxable income.


Definitions:

Collateral Promise

A collateral promise is a secondary agreement that one party will assume responsibility for another's debt or obligation if that other party fails to fulfill it.

Secondary Obligations

Duties or liabilities that arise not from the primary contract but as a result of ancillary or supplementary agreements or circumstances.

Statute of Frauds

A legal concept that requires certain types of contracts to be in writing and signed by all parties involved to be enforceable.

Written Contract

An agreement between two or more parties that is expressed in written form and is intended to be enforceable by law.

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