International School of Paris

“There are two international school of paris legal entities. One is the delaware nonprofit entity filing this form 990 ("isp-us"), and the other is the "real" international school in paris ("isp-france"), which is a not-for-profit french association that operates a school in paris with over 700 students from approximately 60 different countries. Additional information regarding isp-france's organizational structure and its educational operations can be found at https://www.isparis.edu/. Isp-us was originally set up in the 1960s to operate the school in paris because at the time there was no form of french legal entity that was tailored to the purpose of providing english language education in france. Therefore, the school legal entity was set up in the u.s. As a delaware nonprofit corporation and registered to operate the school in france. It applied for and received section 501(c)(3) status in 1973 on this basis. In the early 1980s, france created a new type of legal entity suitable for the school, and the current isp-france was created to operate the school, which it has continued to do to this day. Instead of dissolving isp-us when isp-france took over the school operations, isp-france maintained the delaware entity to raise us tax-deductible contributions for distribution to isp-france. Rather than restructuring isp-us as a "friends organization" following the guidelines set forth in rev. Ruls. 63-252 and 66-79, it continued to file forms 990 as if isp-us was operating the school. Therefore, from the early 1980s forward, isp-us was a phantom, alter ego of isp-france -- that is, (i) its name was identical to the isp-france name, (ii) it had the same august 31 fiscal year as isp-france, (iii) on its forms 990 it reported the same income, expenses, assets and liabilities as those of isp-france, and (iv) its officers and directors were at all times the same as those of isp-france. Each year, someone at isp-france prepared and filed isp-us's forms 990 in a timely fashion mirroring isp-france's income, expense, assets and liabilities. Isp-france recently decided to dissolve isp-us, and during the dissolution process us legal counsel noticed the fact that the forms 990 that it had filed for many years were incorrect because isp-us, as a phantom legal entity, had no income, expenses, assets or liabilities. Accordingly, isp-us is filing this form 990 on a zero-dollar basis to reflect the true nature of its operational structure. In this regard, please be advised that on february 14, 2022, isp-us made a voluntary disclosure to the irs regarding its past form 990 filings and filed a request for a closing agreement pursuant to irm 4.75.25 with brett dietrich, an official in the te/ge division's national office. Mr. Dietrich's telephone number is 801-620-4313, and his email address is [email protected]. He has said that he would be willing and able to discuss the filing of this zero-dollar form 990 with your office if you believe that it would be helpful.”

“Given that since the early 1980s the organization has never had any income, expenses, assets or liabilities, and has never conducted any activities, there is not an appropriate public charity box to check, and the organization is clearly not a private foundation. Therefore, because the organization needs to check a box in order to complete the form, it has chosen to check the line 2 school box even though it did not operate a school during the august 31, 2021, tax year.”