 My name is Shyam Subramanian and today I'll be talking about the public support test. Most international NGOs that are seeking to be deemed equivalent to a 503 public charity must meet a mathematical public support test. Now an organization may be able to qualify without meeting this public support test, but these situations are rare and so we're not going to discuss them today. For an organization to meet the public support test, generally speaking means that it is funded by and therefore accountable to the general public. If the organization is funded by a few private donors such as a few individuals or one large corporation then it is not likely to meet the public support test. Now what's important about this test is that it looks at whether the organization is funded by a diverse range of sources rather than a few private donors. An organization that is exclusively funded by a few private individuals or a large corporation for example is not considered sufficiently accountable to the public. If a charity is funded by a few private donors it might be considered a private foundation. In the United States that means that there are additional restrictions on their activities and their expenditures and for foreign public charity equivalents it means that a U.S. grantmaker such as a private foundation and a donor advice fund must exercise expenditure responsibility when making grants to them. This is often more burdensome for the grantor as well as the grantee. Now before we get into the specific requirements of the public support test it's important to note that these rules are complex so this is intended to be a high-level overview only. Only speaking contributions from the government and from U.S. charitable organizations are counted in full as public support. Other sources of income such as from individuals, non-charitable organizations, for-profit corporations for example, are capped at two percent. And there are actually two types of public support tests. The most common one that organizations will qualify under is 509A1 of the Internal Revenue Code or here A1 for short. Generally speaking an organization has to show that at least 33 and a third percent of its support is public support or at least 10 percent of its income is from public support of public sources. The charity actively seeks funds and it also meets some other sets of facts and circumstances. For example it operates programs that benefit the public, members are involved in carrying out its programs and it has a board that is representative of the community that it serves. Now the 509A2 or A2 for short test is less common and this would generally apply to organizations that receive the majority of their income from mission related activities or gross receipts from mission related activities. So examples of this type of income would be admission fees to a museum or a zoo or course fees for educational courses. What's important about both of these tests is that a charity cannot be primarily supported by investment income or unrelated business income. And unrelated business income generally speaking is income from a trader business that does not serve to further the organization's purpose other than a source of revenue. So an example of this might be an organization sells commercial advertising and it receives revenue from this. So if an organization is funded by a number of small donors or is primarily supported by the government and it's not primarily supported by investment income or unrelated business income then it is likely to pass the public support test. On the other hand if the charity is primarily supported by a single donor, a family or a business or it is primarily funded by investment income then it is unlikely to pass the public support test. And stepping back again the purpose of this test is to determine whether the organization based on its income seems to be funded by and accountable to the general public. These rules are complex but fortunately we have a variety of resources on our website ngosource.org and you can also email us if you have any specific questions about equivalency determination in general or the public support test in particular.