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44-602: The African Leadership Academy ( ALA ) is an educational institution located in Roodepoort on the outskirts of Johannesburg , South Africa , for students between the ages of 16 and 19 years old, with current alumni coming from 46 countries. Founded in 2004 by Fred Swaniker , Chris Bradford, Peter Mombaur, and Acha Leke , ALA officially opened in September 2008 with an inaugural class of 97 students. ALA seeks to transform Africa by identifying, developing, and connecting

88-545: A safe harbor for 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

132-433: A "Student Enterprise," an "Original idea for Development," or a "Community Service Project." The student-run businesses only operate on campus and include: Original Ideas for Development (OIDs) are projects that have a wide scope and run beyond the students' time at ALA. Current OIDs include: Global Scholars Program is a three-week, global leadership summer program for teens aged 13–19. Students from other countries around

176-496: A 450 seater auditorium, classrooms and a dining hall. In 2016, ALA renovated its dormitories, allowing the school to increase the number of students in each class by 30%. The African Leadership Academy receives several thousand applications during the first round, where approximately 400 are selected to attend finalist events held across the continent. The finalists then write entrance exams, participate in group activities and are interviewed. 120 students are selected annually to attend

220-509: A candidate in some manner, or (c) favor a candidate or group of candidates, constitute prohibited participation or intervention. Since section 501(c)(3)'s political-activity prohibition was enacted, "commentators and litigants have challenged the provision on numerous constitutional grounds", such as freedom of speech , vagueness , and equal protection and selective prosecution. Historically, Supreme Court decisions, such as Regan v. Taxation with Representation of Washington , suggested that

264-595: A choice between two sets of rules establishing an upper bound for their lobbying activities. Section 501(c)(3) organizations risk loss of their 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 subsequently qualify for 501(c)(3) status. Churches must meet specific requirements 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

308-544: A church's principal means of accomplishing its religious purposes must be to assemble regularly a group of individuals related by common worship and faith." The United States Tax Court has stated that, while a church can certainly broadcast its religious services by radio, radio broadcasts themselves do not constitute a congregation unless there is a group of people physically attending those religious services. A church can conduct worship services in various specific locations rather than in one official location. A church may have

352-411: A foreign subsidiary to facilitate charitable work in a foreign country, then donors' contributions to the 501(c)(3) organization are tax-deductible even if intended to fund the foreign charitable activities. If a foreign organization sets up a 501(c)(3) organization for the sole purpose of raising funds for the foreign organization, and the 501(c)(3) organization sends substantially all contributions to

396-444: 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. The Internal Revenue Service has never defined the term "substantial part" with respect to lobbying. To establish

440-783: A manner consistent with a particular religion's religious beliefs does not qualify as a tax-exempt church. 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 on this prohibition: 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

484-467: 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 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 with evidence of bias that (a) favor one candidate over another, (b) oppose

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528-442: A significant number of people associate themselves with the church on a regular basis, even if the church does not have a traditional established list of individual members. In order to qualify as a tax-exempt church, church activities must be a significant part of the organization's operations. An organization whose operations include a substantial nonexempt commercial purposes, such as operating restaurants and grocery stores in

572-423: A significant portion of a church school's curriculum is religious education. For a payment to be a tax-deductible charitable contribution, it must be a voluntary transfer of money or other property with no expectation of procuring financial benefit equal to the transfer amount. Before donating to a 501(c)(3) organization, a donor can consult the searchable online IRS list of charitable organizations to verify that

616-432: A tax deduction on a charitable gift to a 501(c)(3) organization that is organized and operated exclusively for religious, charitable, scientific, literary or educational purposes, or to foster national or international amateur sports competition (but only if no part of its activities involve the provision of athletic facilities or equipment), or for the prevention of cruelty to children or animals. An individual may not take

660-440: A tax deduction on gifts made to a 501(c)(3) organization that is organized and operated exclusively for the testing for public safety. In the case of tuition fees paid to a private 501(c)(3) school or a church school, the payments are not tax-deductible charitable contributions because they are payments for services rendered to the payee or the payee's children. The payments are not tax-deductible charitable contributions even if

704-445: Is a cornerstone of the student experience that creates opportunities to practice leadership and entrepreneurship skills through simulation and project-based learning. Students are encouraged to work on team building and original thinking. In the interdisciplinary African studies curriculum, students study hunger eradication, health care provision, economic growth , and conflict resolution . Inaugural Dean Christopher Situma Khaemba

748-632: Is a four-day conference where participants from secondary schools around the world debate and discuss some of the most complicated issues on the continent. Participants also attend presentations by African Union officials and foreign policy experts. As well as the Board of Trustees, the Academy's Global Advisory Council is composed of African and global luminaries in business, leadership development, secondary education, and social entrepreneurship. The Global Advisory Council provides strategic input and guidance to

792-486: Is a place where people of different ages gain an education , including preschools, childcare, primary-elementary schools, secondary-high schools, and universities. They provide a large variety of learning environments and learning spaces . Educational architecture, school architecture or school building design is a discipline which practices architect and others for the design of educational institutions, such as schools and universities , as well as other choices in

836-557: Is a searchable database of information about organizations over time. WikiCharities, is a nonprofit database of nonprofits and charities by name, location, and topic, that allows each organization to report its financials, leadership, contacts, and other activities. Section 501(c)(3) organizations are prohibited from supporting political candidates, as a result of the Johnson Amendment enacted in 1954. Section 501(c)(3) organizations are subject to limits on lobbying , having

880-434: Is allowed to award grants to foreign charitable organizations if the grants are intended for charitable purposes and the grant funds are subject to the 501(c)(3) organization's control. Additional procedures are required of 501(c)(3) organizations that are private foundations . Donors' contributions to a 501(c)(3) organization are tax-deductible only if the contribution is for the use of the 501(c)(3) organization, and that

924-800: 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

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968-478: Is not required to be made available to the public, unless the organization is an independent foundation. Churches are generally exempt from this reporting requirement. Every 501(c)(2) organization must make available for public inspection its application for tax-exemption, including its Form 1023 or Form 1023-EZ and any attachments, supporting documents, and follow-up correspondence with the Internal Revenue Service. The same public inspection requirement applies to

1012-555: 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. A 501(c)(3) organization is allowed to conduct some or all of its charitable activities outside the United States. A 501(c)(3) organization

1056-406: 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: The IRS released a software tool called Cyber Assistant in 2013, which was succeeded by Form 1023-EZ in 2014. There is an alternative way for an organization to obtain status if an organization has applied for a determination and either there

1100-467: 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 or nonprofit corporate bylaws. This limiting of

1144-434: The 14-point list is a guideline; it is not intended to be all-encompassing, and other facts and circumstances may be relevant factors. Although there is no definitive definition of a church for Internal Revenue Code purposes, in 1986 the United States Tax Court said that "A church is a coherent group of individuals and families that join together to accomplish the religious purposes of mutually held beliefs. In other words,

1188-508: The 15 best emerging social entrepreneurs in the world . In 2007 the initial campus was confirmed, and Christopher Khaemba was announced as the inaugural Dean of the School. The current dean of African Leadership Academy is Derek Smith. The campus is located in Honeydew, on the outskirts of Johannesburg . Students share a dormitory , and there are modern facilities including a sports field,

1232-502: The 501(c)(3) designation. In 1980, the United States District Court for the District of Columbia recognized a 14-part test in determining whether a religious organization is considered a church for the purposes of the Internal Revenue Code: Having an established congregation served by an organized ministry is of central importance. Points 4, 6, 8, 11, 12, and 13 are also especially important. Nevertheless,

1276-405: The 501(c)(3) organization is not merely serving as an agent or conduit of a foreign charitable organization. The 501(c)(3) organization's management should review the grant application from the foreign organization, decide whether to award the grant based on the intended use of the funds, and require continuous oversight based on the use of funds. If the donor imposes a restriction or earmark that

1320-547: The ALA management team. The African Leadership Foundation is a USA 501(c)(3) non-profit foundation that supports the African Leadership Academy and the next generation of African leaders. 26°04′31″S 27°54′58″E  /  26.075376°S 27.916067°E  / -26.075376; 27.916067 Educational institution This is an accepted version of this page An educational institution

1364-464: The Academy. Admissions status is usually finalized by mid-April. The African Leadership Academy uses four criteria for admitting students annually. African Leadership Academy uses: The academic core combines a two-year pre-university program based on the Cambridge A Levels and Entrepreneurial Leadership, African Studies and Writing and Rhetoric. ALA's primary entrepreneurial leadership curriculum

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1408-548: The Court, if it were to squarely examine the political-activity prohibition of § 501(c)(3), would uphold it against a constitutional challenge. However, some have suggested that a successful challenge to the political activities prohibition of Section 501(c)(3) might be more plausible in light of Citizens United v. FEC . In contrast to the prohibition on political campaign interventions by all section 501(c)(3) organizations, public charities (but not private foundations) may conduct

1452-432: The Internal Revenue Service. Prior to October 9, 1969, nonprofit organizations could declare themselves to be tax-exempt under Section 501(c)(3) without first obtaining Internal Revenue Service recognition by filing Form 1023 and receiving a determination letter. A nonprofit organization that did so prior to that date could still be subject to challenge of its status by the Internal Revenue Service. Individuals may take

1496-405: The contribution must be used for foreign activities, then the contribution is deemed to be for the foreign organization rather than the 501(c)(3) organization, and the contribution is not tax-deductible. The purpose of the grant to the foreign organization cannot include endorsing or opposing political candidates for elected office in any country. If a 501(c)(3) organization sets up and controls

1540-755: The educational design of learning experiences. The design of building can significantly influence the learning experience of students. Additionally, because schools are important sources of traffic, employment and community activities, school buildings often act as anchor institutions in neighborhoods or communities. The decline of a school can have significant impact on local communities. Types of educational institution include: 501(c)(3)#501.28c.29.283.29 501(c)(3) tax-exemptions apply to entities that are organized and operated exclusively for religious , charitable , scientific , literary or educational purposes, for testing for public safety , to foster national or international amateur sports competition, or for

1584-503: The next generation of African leaders. To achieve this goal, ALA teaches a two-year curriculum in African Studies , Writing, Rhetoric and Entrepreneurial Leadership , as well as the usual academic core subjects. Around 2004, the founders of ALA, launched Global Leadership Adventures , a summer program that would be a precursor to ALA. In 2006, Swaniker and Bradford were recognized by Echoing Green, who described them as two of

1628-515: 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

1672-435: The organization qualifies to receive tax-deductible charitable contributions. 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) organization. Most 501(c)(3) must disclose the names and addresses of certain large donors to the Internal Revenue Service on their annual returns, but this information

1716-840: The organization's annual return, namely its Form 990 , Form 990-EZ, Form 990-PF, Form 990-T, and Form 1065, including any attachments, supporting documents, and follow-up correspondence with the Internal Revenue Service, with the exception of the names and addresses of donors on Schedule B. Annual returns must be publicly available for a three-year period beginning with the due date of the return, including any extension of time for filing. The Internal Revenue Service provides information about specific 501(c)(3) organizations through its Tax Exempt Organization Search online. A private nonprofit organization, GuideStar , provides information on 501(c)(3) organizations. ProPublica's Nonprofit Explorer provides copies of each organization's Form 990 and, for some organizations, audited financial statements. Open990

1760-409: 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 an $ 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

1804-676: The prevention of cruelty to children or animals . 501(c)(3) exemption applies also for any non-incorporated community chest , fund, cooperating association or foundation organized and operated exclusively for those purposes. There are also supporting organizations—often referred to in shorthand form as "Friends of" organizations. 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 of $ 250 or more). Due to

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1848-503: The tax deductions associated with donations, loss of 501(c)(3) status can be highly challenging if not fatal to a charity's continued operation, as many foundations and corporate matching funds 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 tax deduction for contributions. The two exempt classifications of 501(c)(3) organizations are as follows: The basic requirement of obtaining tax-exempt status

1892-401: The world get the chance to come to ALA, and they learn more about the continent as well as skills related to leadership and entrepreneurship. A study abroad experience for secondary students from around the world to develop as social innovators. Students can choose to take a trimester or a full year at ALA, where they can take the core subjects and engage in different activities on campus. MAU

1936-487: Was previously Principal of Alliance High School on the outskirts of Nairobi , Kenya. Khaemba received his MBA from Kenyatta University in Nairobi. The current Dean of the Academy is Derek Smith. Students are encouraged to participate in a fitness activity. Current competitive sports include soccer, basketball, and volleyball. Students participate in a variety of clubs, and each student is expected to create or run either

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