Diamond Resorts International Foundation

“Business Relationship - THE DIRECTORS AND OFFICERS OF DIAMOND RESORTS INTERNATIONAL FOUNDATION ARE ALL CURRENTLY EMPLOYED BY DIAMOND RESORTS CENTRALIZED SERVICES COMPANY”

“There are no committees with the authority to act on behalf of the governing body.”

“The form 990 is provided to all members of the board of directors for review before filing.”

“To ensure the foundation operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted. The periodic reviews shall, at a minimium, include the following subjects: (a)whether compensation arrangements and benefits are reasonable based on competent survey information, and the result of arm's length bargaining; (b) whether partnerships, joint ventures, and arrangements with management foundations conform to the foundation's written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement, impermissible private benefit or in an excess benefit transaction. In connection wtih any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the directors and members of committees considering the proposed transaction or arrangement. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the board of directors' meeting while the determination of a conflict of interest is discussed and voted upon. The remaining directors shall decide if a conflict of interest exists.”

“Governing documents, conflict of interest policy, and financial statements are made available to the public upon request.”

“Taxpayer hereby makes the de minimis safe harbor election under treasury regulation 1.263(a)-1(f) for all eligible amounts paid or incurred during the taxable year. Taxpayer hereby elects to capitalize repairs and maintenance costs under treasury regulation 1.263(a)-1(n). The costs were incurred during the taxable year in the electing taxpayer's trade or business and the electing taxpayer treats such costs as capital expenditure on its books and records.”