River Park Community Corp

Schedule D, Part X, Line 2 FIN 48 (ASC 740) footnote

“River Park Community Corporation is included in consolidated audited financials statements under the University of Dayton. Below is the FIN 48 (ASC 740) footnote from those financial statements. The University is recognized by the Internal Revenue Service (IRS) as an organization exempt from federal taxation under Section 501(c)(3) of the Internal Revenue Code (IRC). The University is a public charity as defined by IRC Section 170(b)(1)(A)(ii). The University is exempt from federal income taxes except to the extent of income derived from unrelated business activities. Unrelated business income is not material to the financial statements. The entities for which the University is the sole member are disregarded for tax purposes. Any activity from these entities is included in the tax return of the University. The River Park Community Corporation has been recognized by the Internal Revenue Service as a title holding corporation exempt from federal taxation under Section 501(c)(2) of the IRC. The River Park Community Corporation is exempt from federal income taxes except to the extent of income derived from unrelated business activities. Unrelated business income is not material to the financial statements. Tax returns filed by the University and River Park Community Corporation are subject to examination by the IRS up to three years from the filing date of each return. Forms 990 and 990T filed by the entities are no longer subject to examination for the years 2020 and prior. The University completed an analysis of its tax position, in accordance with Accounting Standards Codification (ASC) 740, Income Taxes, and determined that no amounts were required to be recognized in the consolidated financial statements as of June 30, 2024 or 2023.”