Chestnut Health Qalicb Inc

PART X, LINE 2:

“Chestnut has received a tax determination letter from the internal revenue service stating that chestnut qualifies under the provisions of section 501(c)(3) of the irc and is exempt from federal income taxes. As such, chestnut is subject to federal income taxes only on any net unrelated business income under the provisions of section 511 of the irc. Chestnut files a form 990 (return of organization exempt from income tax) 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 organizations include such matters as the following: the tax-exempt status of each entity and various positions relative to potential sources of unrelated business taxable income (ubit). Ubit is reported on form 990-t, as appropriate. The benefit of a tax position is recognized in the consolidated 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 is 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. There were no uncertain tax benefits identified and recorded as a liability as of june 30, 2020 and 2019.”