Randolph Foundation

In 2003 a confusing deal, described in The Randolph Foundation's 2003 IRS 990, was made by The Randolph Foundation and The Smith Richardson Foundation (SRF). The deal created a new The Randolph Foundation with a new EIN (47-0892971), transferred all of the old The Randolph Foundation's assets - $49 million - to the new entity, renamed the old The Randolph Foundation to the H. Smith Richardson Charitable Trust (HSRCT), and transferred $48 million from the Smith Richardson Foundation to HSRCT (essentially replacing the money given to the new The Randolph Foundation). The agreement setup a deal whereby the HSRCT gave money to the Smith Richardson Foundation each year that the SRF would then disburse - and which would report the grants in its IRS 990. For that reason we will not be including HSRCT grants in our database.

Questions about the curious arrangement were not answered by people either at the new HSRCT or the Smith Richardson Foundation. For example, why would the SRF give $48 million to HSRCT, only to have HSRCT give it back to SRF, year by year, to dispurse as SRF sees fit?

After 2003, the Randolph Foundation has a new EIN of 47-0892971. It's old EIN, 23-7245123, now belongs to the HSRCT.

The following is from the old The Randolph Foundation (listed as HSRCT in the 990 - with the same EIN) IRS 990 from 2003:

H. SMITH RICHARDSON CHARITABLE TRUST
EIN: 23-7245123
FORM 990PF
TAX YEAR ENDED 12/31/2003

FORM 990PF PART VII-A QUESTION 5

The various transfers between private foundations contained in this return were the result of a settlement agreement reached between all of the parties involved. Through the years there have been numerous legal disputes between and among these various parties. Such disputes have resulted in extensive litigation in certain state courts. The various parties, including the Attorney Generals in the applicable states, executed a settlement agreement to resolve all disputes and litigation. A key component of this settlement agreement is the transfers of assets among the various private foundations. The Internal Revenue Service (IRS) reviewed the transfers contained in this return when they were originally proposed, and the service ruled on them in the attached private letter ruling (PLR). This return has been prepared in accordance with that ruling (statement 21).

Prior to May 8, 2003 this entity was known as The Randolph Foundation. On May 8, 2003 The Randolph Foundation transferred 100% of its assets (fair market value of $49,036,069 - see Statement A for a complete listing) to a new private foundation. The new entity that received the assets is now called The Randolph Foundation (EIN 47-0892971). The address of the new Randolph Foundation is 255 East 49th Street, Suite 23D, New York, NY 10017. The transfer of 100% of assets is an Internal Revenue Service Code (IRC) Section (§)507(b)(2) transfer according to ruling number 4 of the attached PLR. Also according to ruling number 4, the new Randolph Foundation entity is treated as the successor to the old Randolph Foundation entity for purposes of IRS Chapter 42 and §'s 507 through 509.

After the transfer of 100% of the assets to the new Randolph Foundation this entity was renamed H. Smith Richardson Charitable Trust (EIN 23-7245123). Also, after this entity was renamed, the Smith Richardson Foundation, Inc. (EIN 56-0611550) made a capital endowment grant under Treasury Regulation (Treas. Reg.) §53.4945(c)(2) to the H. Smith Richardson Charitable Trust in the amount of $48,406,981.

RELATED LINKS

Internal Links

External Links

FUNDER PROFILE

Randolph Foundation