508(c)(1)(a) Status

Helix BioMedical is organized and operates as a 508(c)(1)(a) faith-based healthcare ministry under the Internal Revenue Code of 1986, as amended. This document explains the legal basis and practical implications of our organizational status, our tax-exempt standing, the rights of our donors, our governance structure, and our voluntary commitments to transparency and accountability. This information is provided for the benefit of patients, donors, partners, regulatory agencies, and the communities we serve.

1. What 508(c)(1)(a) Means

Section 508(c)(1)(a) of the Internal Revenue Code provides that churches, their integrated auxiliaries, and conventions or associations of churches are exempt from federal income tax as a matter of law, without the need to apply for recognition of that status from the Internal Revenue Service. Specifically, 26 U.S.C. 508(c)(1)(a) states that the requirements of Section 508(a) -- which generally require organizations seeking tax-exempt status to notify the IRS -- "shall not apply to churches, their integrated auxiliaries, and conventions or associations of churches." This means that such organizations are treated as tax-exempt under Section 501(c)(3) of the Internal Revenue Code automatically, by operation of law, from the date of their formation, without any filing, application, or approval from the IRS.

The term "church" for these purposes is not limited to traditional houses of worship. Federal courts and the IRS have recognized that a wide range of religious organizations qualify as churches under the Internal Revenue Code. The IRS uses a multi-factor test (sometimes called the "14 Points" test) that considers factors including: a distinct legal existence; a recognized creed and form of worship; a definite and distinct ecclesiastical government; a formal code of doctrine and discipline; a distinct religious history; a membership not associated with any other church or denomination; an organization of ordained ministers; ordained ministers selected after completing prescribed courses of study; a literature of its own; established places of worship; regular congregations; regular religious services; Sunday schools or an equivalent for religious instruction; and schools for the preparation of its ministers. Helix BioMedical satisfies the relevant criteria for classification as a church and operates as an ecclesiastical healthcare ministry.

2. Legal Basis and Authority

2.1 Statutory Authority

Our tax-exempt status is grounded in the following statutory provisions:

• 26 U.S.C. 501(c)(3): Provides income tax exemption for organizations organized and operated exclusively for religious, charitable, scientific, or educational purposes;
• 26 U.S.C. 508(c)(1)(a): Exempts churches, integrated auxiliaries, and conventions or associations of churches from the application and notification requirements otherwise applicable to organizations seeking 501(c)(3) recognition;
• 26 U.S.C. 170(b)(1)(A)(i): Designates contributions to churches as deductible charitable contributions for federal income tax purposes;
• 26 U.S.C. 6033(a)(3)(A)(i): Exempts churches from filing the annual Form 990 information return required of most other exempt organizations; and
• 26 U.S.C. 7611: Places special restrictions on IRS examinations of churches, requiring high-level IRS approval before a church tax inquiry may be initiated and imposing strict procedural requirements on such inquiries.

2.2 First Amendment Protections

Our status as a church-based organization also implicates important constitutional protections under the First Amendment to the United States Constitution, which protects the free exercise of religion and prohibits government establishment of religion. Courts have long recognized that application of certain tax laws and regulatory requirements to churches raises significant First Amendment concerns and have accordingly interpreted such laws narrowly when applied to religious organizations. We retain and assert these constitutional protections in the conduct of our ministry activities.

2.3 Wyoming Law

Helix BioMedical is organized under the laws of the State of Wyoming. Wyoming provides a favorable legal environment for religious organizations, with strong protections for religious liberty under state law. Our organizational documents -- including our Articles of Organization and Governing Bylaws -- are filed with the Wyoming Secretary of State and are available for inspection upon written request.

3. Comparison to 501(c)(3) Organizations

Many donors and partners are familiar with 501(c)(3) organizations, which make up the majority of U.S. tax-exempt nonprofits. It is helpful to understand how 508(c)(1)(a) organizations differ from and are similar to 501(c)(3) organizations:

3.1 Similarities

• Both are exempt from federal income tax under Section 501(c)(3);
• Both may receive tax-deductible charitable contributions from donors under Section 170;
• Both are prohibited from distributing earnings to any private shareholder or individual;
• Both are prohibited from intervening in political campaigns on behalf of or in opposition to any candidate for public office; and
• Both must be organized and operated primarily for exempt purposes.

3.2 Key Differences

• Application requirement: 501(c)(3) organizations must file Form 1023 or Form 1023-EZ with the IRS and receive a formal determination letter. 508(c)(1)(a) churches are exempt automatically and do not file Form 1023;
• Annual reporting: Most 501(c)(3) organizations must file annual Form 990 information returns. Churches are exempt from this requirement under Section 6033;
• IRS audit procedures: IRS examinations of 501(c)(3) organizations follow standard audit procedures. Examinations of churches are subject to the heightened procedures of Section 7611, which require high-level IRS approval and impose significant procedural restrictions; and
• IRS database: 501(c)(3) organizations with formal determination letters appear in the IRS Tax Exempt Organization Search database. Churches automatically exempt under Section 508(c)(1)(a) do not appear in this database, which is consistent with their statutory status.

4. Tax-Exempt Status

4.1 Federal Income Tax Exemption

As a 508(c)(1)(a) faith-based organization, Helix BioMedical is exempt from federal income tax on income derived from activities that are substantially related to our exempt purposes. This includes income from patient care services provided in furtherance of our charitable healthcare mission, charitable contributions and donations, grants for healthcare or educational programs, program service revenue from educational offerings, and investment income held for charitable purposes.

Income from activities that are not substantially related to our exempt purposes (i.e., "unrelated business income") would in principle be subject to the unrelated business income tax (UBIT) under Sections 511-514 of the Code. We structure our activities to ensure that substantially all of our revenue derives from activities that are substantially related to our exempt healthcare and educational mission.

4.2 Employment Taxes

As a church, we are entitled to elect exemption from the Federal Insurance Contributions Act (FICA) for services of ordained ministers and certain other church employees, provided applicable requirements are met. We consult with qualified tax counsel to ensure proper treatment of all employment tax obligations.

4.3 State and Local Tax Exemption

Our federal 508(c)(1)(a) status generally supports state and local tax exemption applications, although state tax exemptions require separate applications in most jurisdictions. We have applied for and maintain applicable state and local tax exemptions in the jurisdictions where we operate, including property tax exemptions for real property used in furtherance of our charitable and religious mission, and sales tax exemptions for purchases made in connection with our exempt activities. The availability and scope of state and local tax exemptions vary by jurisdiction.

5. Our Faith-Based Healthcare Mission

5.1 Foundational Beliefs

Helix BioMedical was founded on the conviction that healing is a sacred calling and that access to quality healthcare is a matter of human dignity. Our faith-based mission is expressed through every aspect of our work: the way we treat patients, the communities we choose to serve, the programs we design, and the standards of compassion and excellence we hold ourselves to. We believe that every human being, regardless of their background, beliefs, or circumstances, is worthy of dignified, high-quality care.

5.2 Ministry Activities

Our ministry activities include: operating mobile medical clinics that travel to underserved communities to provide primary and preventive care, diagnostics, vaccinations, and health screenings at no cost to patients; providing charitable care and financial assistance to patients who cannot afford to pay for services; conducting community health education programs that empower individuals to make informed decisions about their health; offering faith-informed counseling and support to patients facing serious illness or end-of-life concerns; training healthcare workers and community health educators through our educational programs; conducting research to advance understanding of disease prevention and treatment in underserved populations; and advocating for policies that expand access to healthcare for all people.

5.3 Integration of Faith and Healthcare

Our faith informs but does not limit our healthcare practice. We serve all people without regard to their faith tradition or lack thereof. We do not require patients or students to share our beliefs as a condition of receiving services or participating in programs. Where our faith commitments affect the scope of specific services we offer, we clearly communicate this to individuals and provide referrals to other providers for any services we do not offer.

6. Governance Structure

6.1 Board of Trustees

Helix BioMedical is governed by a Board of Trustees that provides strategic oversight, ensures mission alignment, and holds leadership accountable. The Board is composed of individuals who are committed to our faith-based mission and who bring expertise in healthcare, law, finance, community development, and faith leadership. Board members serve fixed terms and are subject to term limits as specified in our bylaws.

6.2 Board Responsibilities

The Board of Trustees is responsible for: establishing and upholding the mission, vision, and values of the organization; selecting, evaluating, and if necessary, removing the executive leadership team; approving annual operating and capital budgets; reviewing and approving major organizational policies, including financial controls, conflict of interest policies, and whistleblower protections; overseeing legal and regulatory compliance, including healthcare licensure, HIPAA compliance, and charitable solicitation requirements; ensuring the integrity of financial reporting; approving major transactions, including real property acquisitions and significant contracts; and providing community accountability for the organization's programs and outcomes.

6.3 Conflict of Interest Policy

All members of the Board of Trustees and senior leadership team are required to annually disclose all actual and potential conflicts of interest in accordance with our Conflict of Interest Policy. Individuals with a material conflict of interest are required to recuse themselves from discussion and voting on matters in which they have a conflict. We maintain written records of all conflict disclosures and recusals.

6.4 Compensation

No part of the net earnings of Helix BioMedical inures to the benefit of, or is distributable to, any trustee, officer, employee, donor, or any other private individual. Compensation paid to employees and officers is reasonable and commensurate with services rendered, consistent with the standards applicable to 501(c)(3) organizations under the intermediate sanctions rules of Section 4958 of the Code. The Board reviews and approves all compensation arrangements for senior leadership.

7. Donor Rights and Protections

7.1 Donor Bill of Rights

Helix BioMedical subscribes to the Donor Bill of Rights, developed by the Association of Fundraising Professionals (AFP) and other national charitable organizations. This means we commit to the following donor rights:

• The right to be informed of our organization's mission, the way we intend to use donated resources, and our capacity to use donations effectively;
• The right to receive our most recent financial statements upon request;
• The right to be assured that gifts will be used for the purposes for which they were given;
• The right to receive appropriate acknowledgment and recognition;
• The right to have confidence that information about your donation will be handled with respect and privacy;
• The right to expect that all relationships with our organization will be professional in nature;
• The right to be informed whether those seeking donations are volunteers, employees, or contracted agents; and
• The right to have the opportunity to have their names deleted from mailing lists that the organization may intend to share.

7.2 Restricted Gifts

Donors who wish to restrict their gift to a specific program or purpose may do so by indicating the restriction in writing at the time of the gift. We will honor all gift restrictions that are consistent with our organizational mission and that are practically administrable. Gifts that cannot be used for the designated purpose -- for example, because the designated program is discontinued -- will be redirected to the purpose that most closely aligns with the donor's intent, as determined by the Board of Trustees.

7.3 Endowment and Planned Giving

Donors interested in making a planned gift -- including bequests, charitable remainder trusts, charitable lead trusts, gift annuities, or beneficiary designations -- should contact our development office at [email protected] or (702) 825-0288. We work with donors and their advisors to structure planned gifts that achieve the donor's philanthropic and financial objectives while advancing our mission.

8. Donation Acknowledgment and Tax Substantiation

8.1 Written Acknowledgment Requirements

Under 26 U.S.C. 170(f)(8), donors who make a charitable contribution of $250 or more in a single contribution must obtain a contemporaneous written acknowledgment from the charitable organization to substantiate the deduction. "Contemporaneous" means the acknowledgment must be received on or before the earlier of: the date the donor files their original tax return for the year of the contribution, or the due date (including extensions) of that return.

We will provide a written acknowledgment for every donation of $250 or more within 30 days of receiving the gift. Our acknowledgment will state: the date of the contribution; the amount of any cash contribution; a description (but not value) of any non-cash contribution; and whether any goods or services were provided in exchange for the contribution, and if so, a good faith estimate of their value. If no goods or services were provided in exchange for the gift -- which is the case for the great majority of donations we receive -- the acknowledgment will state: "No goods or services were provided in exchange for this contribution."

8.2 Quid Pro Quo Contributions

If a donor makes a payment to us that is partly a charitable contribution and partly a payment for goods or services (a "quid pro quo contribution") in excess of $75, we will provide a written disclosure statement informing the donor of: the amount of the contribution that is deductible for federal income tax purposes, and a good faith estimate of the fair market value of the goods or services provided. Donors may not deduct the portion of a quid pro quo contribution that represents payment for goods or services received.

8.3 Non-Cash Contributions

Donors who contribute non-cash property -- including real estate, vehicles, securities, or personal property -- with a claimed value exceeding $500 must file Form 8283 with their tax return. For non-cash contributions exceeding $5,000, an independent qualified appraisal is generally required. We will sign the acknowledgment portion of Form 8283 upon request for qualifying non-cash contributions. We do not provide valuations of donated property; donors are responsible for determining and documenting the fair market value of non-cash gifts.

9. State Charitable Solicitation Compliance

Most states require organizations that solicit charitable contributions from their residents to register with the state's charity regulator and to file annual financial reports. Churches and religious organizations are exempt from these requirements in many states. We review the charitable solicitation laws of each state where we conduct fundraising activities and comply with applicable registration and reporting requirements, including any requirements that apply notwithstanding our religious organization status.

In states where we are registered, our registration information -- including the name and contact information of the state charity regulator and our registration number -- is available upon request. In states where we are exempt from registration, we will provide documentation of the applicable exemption upon request. We do not solicit contributions from residents of states where we have not complied with applicable charitable solicitation laws.

10. Voluntary Transparency Commitments

Although 508(c)(1)(a) churches are exempt from many public disclosure requirements that apply to other nonprofits -- including the requirement to file and publicly disclose Form 990 -- Helix BioMedical voluntarily maintains the following transparency practices as a matter of organizational integrity and public trust:

• Annual financial review: Our financial statements are reviewed annually by an independent certified public accounting firm, and we make the review report available to donors and other interested parties upon request;
• Program effectiveness reporting: We publish an annual Ministry Report describing our programs, the communities we serve, and metrics of our impact, including numbers of patients served, educational participants, and community health events conducted;
• Governance document availability: Our Articles of Organization, Bylaws, Conflict of Interest Policy, and Whistleblower Protection Policy are available to any interested party upon written request;
• Compensation disclosure: Upon request, we disclose the compensation of our five highest-paid employees, consistent with the disclosure practices of Form 990-filing organizations;
• Complaint process: We maintain a documented process for receiving and addressing concerns from donors, patients, students, and community members about our programs, finances, or governance; and
• Healthcare regulatory compliance: We fully comply with all applicable healthcare regulatory requirements, including HIPAA, state clinical licensing requirements, and federal healthcare fraud and abuse laws, and we submit to applicable regulatory oversight and audits.

11. Verification of Our Status

Donors, partners, and other stakeholders sometimes ask how to verify the tax-exempt status of a 508(c)(1)(a) organization, given that such organizations do not appear in the IRS Tax Exempt Organization Search (TEOS) database. The absence of a 508(c)(1)(a) church from the TEOS database is not an indication of non-compliance; it is the correct and expected result of our automatic exemption under Section 508(c)(1)(a).

To verify our status, we can provide upon written request:

• A Declaration of 508(c)(1)(a) Status, signed by an authorized officer of the organization;
• Our Articles of Organization filed with the Wyoming Secretary of State;
• Our Statement of Faith and Ministry Purpose;
• Documentation of our religious history and ecclesiastical governance;
• Written confirmation of our Employer Identification Number (EIN); and
• A legal opinion letter from our organizational counsel regarding our 508(c)(1)(a) status, if required by a prospective institutional donor or governmental agency.

We recommend that institutional donors -- including foundations, corporations, and government agencies -- consult with their own legal counsel to satisfy themselves regarding the deductibility of gifts to our organization and any other due diligence requirements applicable to their grant-making or donation programs.

12. Contact Information

For questions about our 508(c)(1)(a) status, governance, charitable programs, donation acknowledgment, or any other matter described in this document, please contact us:

• Email: [email protected]
• Phone: (702) 825-0288
• Organization: Helix BioMedical, a 508(c)(1)(a) faith-based healthcare organization, Wyoming jurisdiction

We are committed to responding to all inquiries about our organizational status promptly and transparently. If we cannot answer your question directly, we will refer you to appropriate legal resources or to our organizational counsel who can provide more detailed information.