The HiRoad Foundation

The concept of using an Irrevocable Charitable Trust as a legal entity, which owns the position as an independent agent of a company which uses network marketing in the development of its product or services distribution structure, is at the core of this program. The concept was initially developed by Bill Pulscher, a minister, whose desire was to create ongoing funding for churches without directly involving them in a for-profit business which could potentially put them at risk of losing their non-profit status.

The HiRoad Foundation was established to foster collaborations, provide resources & facilitate the efforts of non-profits. To this end, one of our concepts is to assist charities and non-profits in the creation of continuous funding revenues from expenditures that their support base is already spending in their daily personal and family lifestyles. The HiRoad Foundation has joined with the Seedlings Foundation to create the venues which establish stewardship.

At the end of this page you can read the applicable sections of the IRS Code establishing the tax- exempt status of the trusts that are developed for this purpose:

Any qualified non-profit can benefit from having an irrevocable charitable trust in place to enable the establishment of stewardship programs. Currently, The HiRoad Foundation is working actively with several marketing groups to create these tools. If you do not already have a program you like, let us make a recommendation or two for you.

TITLE 26, Subtitle A, Chapter 1, Subchapter F, Part 1, Sec. 501

Sec. 501.- Exemption from tax on corporations, certain trusts, etc.

(c) List of exempt organizations

(2) Corporations organized for the exclusive purpose of holding title to property, collecting income there from, and turning over the entire amount thereof, less expenses, to an organization which itself is exempt under this section. Rules similar to the rules of subparagraph (G) of paragraph (25) shall apply for purposes of this paragraph.

The possible question of whether or not the irrevocable charitable trust would qualify under the above exemption is addressed by:

TITLE 26, Subtitle D, Chapter 42, Subchapter A, Sec. 4947

Sec. 4947.- Application of taxes to certain nonexempt trusts

(a) Application of tax

(1) Charitable trusts

For purposes of part II of subchapter F of chapter 1 (other than section 508(a), (b), and (c)) and for purposes of this chapter, a trust which is not exempt from taxation under section 501(a), all of the unexpired interests in which are devoted to one or more of the purposes described in section 170(c)(2)(B), and for which a deduction was allowed under section 170, 545(b)(2), 556(b)(2),642(c),2055, 2106(a)(2), or 2522 (or the corresponding provisions of prior law), shall be treated as an organization described in section 501(c)(3). For purposes of section 509(a)(3)(A), such a trust shall be treated as if organized on the day on which it first becomes subject to this paragraph.
The above Sec. 4947 directs us to Sec. 170(c)(2)(B) which establishes the trusts as tax exempt:

TITLE 26, Subtitle A, CHAPTER 1, Subchapter B, Part VI, Sec. 170.

Sec. 170.- Charitable, etc., contributions and gifts

(c) Charitable contribution defined:

For purposes of this section, the term “charitable contribution” means a contribution or gift to or for the use of –

(2) A corporation, trust, or community chest, fund, or foundation –

(B) organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or to foster national or international amateur sports competition (but only if no part of its activities involves the provision of athletic facilities or equipment), or for the prevention of cruelty to children or animals;

(C) no part of the net earnings of which inures to the benefit of any private shareholder or individual; and

(D) which is not disqualified for tax exemption under section 501(c)(3) by reason of attempting to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.

Trust Request Form
TRSTRQST.pdf