Baltimore Tree Trust Inc.

“In 2013, the btt entered into an agreement with the baltimore community foundation, inc. Bcf, a tax-exempt 501c3 organization, to establish an endowment fund with bcf to be known as the baltimore tree trust endowment fund the fund. The purpose of establishing the fund was to encourage and enhance contributions, ensure perpetual continuity, and provide professional investment management of the btt's endowment fund. As part of this agreement, the board of directors of the btt authorized the transfer of its own funds to bcf. The agreement for the fund stipulates that the principal portion of the fund will be held in perpetuity and that an amount of the net annual income earned by the fund, as determined under the bcfs spending policy, will be distributed to the btt for as long as the btt is in existence. If for any reason the btt ceases operations, the agreement with bcf provides that this income will be used for a similar purpose.”

“BTT is a not-for-profit organization that is exempt from income taxes under Section 501(c)(3) of the United States Internal Revenue Code and is recognized as such by the Internal Revenue Service. The provisions included in accounting principles generally accepted in the United States of America provide consistent guidance for the accounting for uncertainty in income taxes recognized in an entitys financial statements and prescribe a threshold of more likely than not for recognition of tax positions taken or expected to be taken in a tax return. The Organization performed an evaluation of uncertain tax positions as of December 31, 2019, and determined that there were no matters that would require recognition in the financial statements or which may have any effect on its tax-exempt status. As of December 31, 2019, the statute of limitations for fiscal years 2016 through 2019 remains open with the U.S. Federal jurisdiction. It is BTTs policy to recognize interest and/or penalties related to uncertain tax positions, if any, in income tax expense.”