On June 5, 2019, the Department of Justice (DOJ) published通知修改to the text of the proposed amendments to California Code of Regulations and certain charity-related registration forms. We wrote on the original proposed amendments to the initial registration Form CT-1 and annual registration renewal Form RRF-1here和here, respectively. The proposed modifications are in response to comments received regarding the proposed amendments and for the purposes of clarification. We were among those who submitted comments to the original proposed amendments and are generally pleased with the changes (most significantly to Form CT-1), though we’ll take a more careful look in the coming days to see if we have additional responses to the modified drafts.

Form CT-1

形成CT-1的修改包括替换引用财政赞助的问题（参见我们对问题的问题的讨论lol电竞彩票here). The question: “Does the organization share revenue or governance with any other non-profit organization (e.g., fiscal sponsorships and affiliations)?” has been changed to “Is the organization undercommon control, does it have aclose connectionwith, or is itrelated to，任何其他非营利组织或营利组织或信托？“当通知提供：

This modification is made in response to public comments that the proposed question, intended to identify closely related organizations, was unclear. The comments also stated that using the examples of fiscal sponsorships and affiliations was unhelpful because those terms are not defined. The modification eliminates those terms and instead uses terms the IRS uses, such as “common control,” “close connection,” and “related to.” The modification also includes definitions in the CT-1 instructions, which largely track the IRS definitions and are necessary for clarity.

“Common control” means you and one or more other organizations or trusts have: (1) a majority of directors, officers, or trustees appointed or elected by the same organization(s) or individuals, (2) a majority of directors, officers, or trustees consisting of the same individuals. Common control also occurs when you and one or more organizations have a majority ownership interest in a corporation, partnership, or trust. “Ownership” means voting power in a corporation, profits interest in a partnership, or beneficial interest in a trust.

“关闭连接”是指组织之间的任何关系：（1）通过共同的董事，官员或受托人或通过权限来控制一个组织或通过批准预算或支出;（2）协调或分享设施，方案，员工或其他活动的行动;或（3）对组织进行大量影响的普通人。

“Related to” an organization means to control or be controlled by an organization. “Control” means (1) to have the power (by the organization or through one or more officers, directors, trustees or agents) to remove and replace (or to appoint, elect, or approve or veto the appointment or election of) the majority of another organization’s directors or trustees, or a majority of members who elect a majority of another organization’s directors or trustees; (2) to own more than 50% of a stock corporation; (3) to own more than 50% of the profits or capital interests or is managing partner, general partner, or managing member of a partnership or LLC; or (4) to own more than 50% of the beneficial interest in a trust.

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If you have any comments regarding the proposed modifications, the DOJ will accept written comments between June 5, 2019 and June 20, 2019. All written comments must be submitted to the DOJ no later than 5:00 p.m. on June 20, 2019, and addressed to either:

James Toma, Supervising Deputy Attorney General
California Department of Justice
Charitable Trusts Section
300 S. Spring St., Suite 1702
洛杉矶，加州90013
Email: James.Toma@doj.ca.gov

Teresa DePaz, Legal Secretary
California Department of Justice
Charitable Trusts Section
300 S. Spring St., Suite 1702
洛杉矶，加州90013
Email: Teresa.DePaz@doj.ca.gov