Rosalind Franklin University Health Clinics

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

“RFUHC received a favorable letter of determination from the Internal Revenue Service concerning its tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. The University has received a favorable letter of determination from the Internal Revenue Service concerning its tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. The University files a Form 990 annually. When these returns are filed , it is highly certain that some positions taken would be sustained upon examination by the taxing authorities, while others are subject to uncertainty about the merits of the tax position taken or the amount of the position that would ultimately be sustained. Examples of tax positions common to universities include such matters as the following: the tax exempt status of each entity and various positions relative to potential sources of unrelated business income tax (UBIT). UBIT is reported on Form 990-T, as appropriate. The benefit of a tax position is recognized in the financial statements in the period during which, based on all available evidence, management believes that it is more likely than not that the position will be sustained upon examination, including the resolution of appeals or litigation processes, if any. Tax positions are not offset or aggregated with other positions. Tax positions that meet the "more likely than not" recognition threshold are measured as the largest amount of tax benefit that is more than 50% likely to be realized on settlement with the applicable taxing authority. The portion of the benefits associated with tax positions taken that exceeds the amount measured as described above would be reflected as a liability for uncertain tax benefits in the accompanying statements of financial position along with any associated interest and penalties that would be payable to the taxing authorities upon examination. As of June 30, 2021 and 2020, there were no uncertain tax positions identified. The University does not expect the total amount of unrecognized tax benefits to significantly change in the next 12 months. Forms 990 and 990-T filed by the University are subject to the examination by the IRS up to three years from the extended due date of each return. Management believes the Forms 990 and 990-T have been filed appropriately. The University would recognize interest and penalties related to unrecognized tax positions in interest and income tax expense, respectively. The University has no amounts accrued for interest or penalties as of June 30, 2021 and 2020.”