Ad Astra School

“Jared j. Birchall, secretary & treasurer, is the managing director of the musk family office, which operates for the benefit of elon musk and his family.”

“The form 990 was prepared by the school's accountant and reviewed by the president. At this time, the form 990 was reviewed in detail and approved for submission to the internal revenue service. Prior to the final form being submitted to the internal revenue service, a copy was provided to all the members of the board of directors.”

“Each director, officer and member of a committee with board delegated powers shall sign a statement which affirms such person has no conflict of interest. To ensure that the corporation operates in a manner consistent with its 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 minimum, include whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length bargaining. The reviews also include whether partnerships, joint ventures, and arrangements with management organizations conform to the corporation'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.”

“The board of directors is responsible for staff development and compensation. The board conducts annual reviews of compensation and benefits, and compares compensation with data on compensation paid by comparable organizations. It is the school's policy to provide compensation that is above the median for comparable organizations, to more effectively attract and retain the highest quality employees. The members of the board of directors draw on their considerable business experience to appropriately evaluate and compensate key employees.”

“Elon musk is a director of the school and a substantial contributor to the school. His five children currently attend the school. The school does not charge tuition to any of its students. However, to avoid any concerns about private benefit, inurement, and any appearance of untoward personal benefit, all contributions by mr. Musk are treated as follows. The equivalent fair market value of the school's tuition is determined by the disinterested members of the board of directors on an annual basis, based on the average tuition rates of similar private schools in california. All contributions by mr. Musk are treated as tuition-equivalent payments for the benefit of his children that attend the school, up to the full value of the tuition that is imputed to his children. These tuition-equivalent payments are considered program service revenue to the school, and mr. Musk will not take a charitable deduction on his income tax return. Any contributions by mr. Musk that exceed the equivalent value of tuition for his children are considered charitable contributions that are deductible for income tax purposes. The school will prepare written substantiation for mr. Musk's contributions reduced by the equivalent value of the school's tuition. In the fiscal year ending 2016, the school determined that the average tuition for similar private schools in california was $28,000 per year. Because mr. Musk's five children currently attend the school, the first $140,000 of mr. Musk's contributions to the school are treated as tuition-equivalent payments for the benefit of his children that attend the school. The balance of mr. Musk's contributions to the school are considered charitable contributions. Mr. Musk has been advised of the rules regarding private benefit and inurement. To the extent any other disqualified persons have students in the school, the board of directors will follow the same policy and procedure. In addition, the school has reached an arrangement with mr. Musk that so long as he is a disqualified person and has children attending the school, he will make annual tuition-equivalent, non-deductible contributions to the school that are no less than the fair market value of the tuition savings.”

“The school is currently tuition-free. If the school eventually charges tuition, it plans to award need-based scholarships to students accepted into the school, generally in the form of gifts. The school will publicize the availability of its scholarships through its brochures, its website, and during the initial family tour of the school. The school has not yet prepared solicitation or announcement materials. When it offers scholarships, the school will maintain adequate records and case histories as required under revenue ruling 56-304.”