(1) an organization described in (other than in clauses (vii) and (viii));
(2) an organization which—
an organization which—
(A) normally receives more than one-third of its support in each taxable year from any combination of—
normally receives more than one-third of its support in each taxable year from any combination of—
(i) gifts, grants, contributions, or membership fees, and
(ii) gross receipts from admissions, sales of merchandise, performance of services, or furnishing of facilities, in an activity which is not an unrelated trade or business (within the meaning of section 513), not including such receipts from any person, or from any bureau or similar agency of a governmental unit (as described in ), in any taxable year to the extent such receipts exceed the greater of $5,000 or 1 percent of the organization’s support in such taxable year,
(B) normally receives not more than one-third of its support in each taxable year from the sum of—
normally receives not more than one-third of its support in each taxable year from the sum of—
(i) gross investment income (as defined in subsection (e)) and
(ii) the excess (if any) of the amount of the unrelated business taxable income (as defined in section 512) over the amount of the tax imposed by section 511;
(3) an organization which—
an organization which—
(A) is organized, and at all times thereafter is operated, exclusively for the benefit of, to perform the functions of, or to carry out the purposes of one or more specified organizations described in paragraph (1) or (2),
(B) is—
is—
(i) operated, supervised, or controlled by one or more organizations described in paragraph (1) or (2),
(ii) supervised or controlled in connection with one or more such organizations, or
(iii) operated in connection with one or more such organizations, and
(C) is not controlled directly or indirectly by one or more disqualified persons (as defined in section 4946) other than foundation managers and other than one or more organizations described in paragraph (1) or (2); and
(4) an organization which is organized and operated exclusively for testing for public safety.
For purposes of this title, if an organization is a private foundation (within the meaning of subsection (a)) on
For purposes of this part, an organization the status of which as a private foundation is terminated under section 507 shall (except as provided in ) be treated as an organization created on the day after the date of such termination.
(1) gifts, grants, contributions, or membership fees,
(2) gross receipts from admissions, sales of merchandise, performance of services, or furnishing of facilities in any activity which is not an unrelated trade or business (within the meaning of section 513),
(3) net income from unrelated business activities, whether or not such activities are carried on regularly as a trade or business,
(4) gross investment income (as defined in subsection (e)),
(5) tax revenues levied for the benefit of an organization and either paid to or expended on behalf of such organization, and
(6) the value of services or facilities (exclusive of services or facilities generally furnished to the public without charge) furnished by a governmental unit referred to in to an organization without charge.
For purposes of subsection (d), the term “gross investment income” means the gross amount of income from interest, dividends, payments with respect to securities loans (as defined in ), rents, and royalties, but not including any such income to the extent included in computing the tax imposed by section 511. Such term shall also include income from sources similar to those in the preceding sentence.
(1) Type III supporting organizations
For purposes of subsection (a)(3)(B)(iii), an organization shall not be considered to be operated in connection with any organization described in paragraph (1) or (2) of subsection (a) unless such organization meets the following requirements:
(A) Responsiveness
For each taxable year beginning after the date of the enactment of this subsection, the organization provides to each supported organization such information as the Secretary may require to ensure that such organization is responsive to the needs or demands of the supported organization.
(B) Foreign supported organizations
(i) In general
The organization is not operated in connection with any supported organization that is not organized in the United States.
(ii) Transition rule for existing organizations
If the organization is operated in connection with an organization that is not organized in the United States on the date of the enactment of this subsection, clause (i) shall not apply until the first day of the third taxable year of the organization beginning after the date of the enactment of this subsection.
(2) Organizations controlled by donors
(A) In general
For purposes of subsection (a)(3)(B), an organization shall not be considered to be—
(i) operated, supervised, or controlled by any organization described in paragraph (1) or (2) of subsection (a), or
(ii) operated in connection with any organization described in paragraph (1) or (2) of subsection (a),
(B) Person described
A person is described in this subparagraph if, with respect to a supported organization of an organization described in subparagraph (A), such person is—
(i) a person (other than an organization described in paragraph (1), (2), or (4) of ) who directly or indirectly controls, either alone or together with persons described in clauses (ii) and (iii), the governing body of such supported organization,
(ii) a member of the family (determined under ) of an individual described in clause (i), or
(iii) a 35-percent controlled entity (as defined in by substituting “persons described in clause (i) or (ii) of ” for “persons described in subparagraph (A) or (B) of paragraph (1)” in subparagraph (A)(i) thereof).
(3) Supported organization
For purposes of this subsection, the term “supported organization” means, with respect to an organization described in subsection (a)(3), an organization described in paragraph (1) or (2) of subsection (a)—
(A) for whose benefit the organization described in subsection (a)(3) is organized and operated, or
(B) with respect to which the organization performs the functions of, or carries out the purposes of.