Skip to main content

Command Palette

Search for a command to run...

DRAFT — pending professional review

NOT LEGAL OR TAX ADVICE. This module is reference material for the HigherSelf Network cohort. Pending Lumina tone review, outside-CPA review, ERISA-counsel review for any Solo 401(k) or ROBS section, and Grace Fields authorization before external publication. Cohort-facing facts use anonymized framing until written consent is on file.

All entities

HigherSelf Network entity

HigherSelf (Nonprofit)

Public-benefit programming, research dissemination, and educational content

Type: 501c3 public charityTax classification: tax exempt under 501c3EIN: Confirm IRS determination letter on file

Tax profile

Operating income pattern

Grants + donations + program-related income

COGS intensity

varies

Headcount target

Mix of W-2 employees and contractors

§ 199A QBI eligibility

n/a (§ 501(c)(3) organization)

UBIT exposure

Active. Track every revenue stream against the substantial-relation test (§ 513).

Default strategies

The strategies most likely to apply to this entity given its type and operating profile. Each strategy below links to its own page with statutory anchor, 2026 limits, eligibility, and documentation.

Intercompany services at arm's length

IRC § 482; Treas. Reg. § 1.482-1 through § 1.482-9

Two HSN entities transact for real services; need IRS-defensible pricing.
Below-market loans — § 7872

IRC § 7872

One HSN entity needs to lend cash to another at AFR with proper documentation.
Excess-benefit safe harbor — § 4958 rebuttable presumption

IRC § 4958; Treas. Reg. § 53.4958-6

Any HigherSelf Nonprofit transaction with a disqualified person (officer, director, substantial contributor, family member).

Default-strategy slugs declared in entities.json: qualified charitable grants out, ubti management section 511, § 4958 rebuttable presumption procedure, qualified sponsorship payments section 513, donor advised funds where applicable

Intercompany role

How this entity transacts with the other three HSN entities and with cohort members. Pricing and documentation must satisfy § 482 arm's-length and § 7872 below-market loan rules.

  • Buys goods and services from HSN entities only at FMV with documented § 4958 rebuttable-presumption procedures
  • Receives no-strings grants from HSN entities and outside donors
  • Cannot be a conduit for tax-free transfers to insiders or cohort members

Constraints

  • No private inurement (any amount)
  • No more than incidental private benefit
  • No substantial lobbying; no political campaign activity
  • UBIT on unrelated business income (§ 511–§ 514)
  • § 4958 excess-benefit transaction taxes: 25% on disqualified person; 10% on knowing manager; 200% if uncorrected
  • Closed-membership cohort programs are NOT charitable contributions — they are fee-for-service

Open questions

Items that require professional confirmation before any cohort-facing implementation. These are the gates this module cannot resolve on its own.

  • Public-charity classification (§ 509(a)(1) vs. (a)(2)) and public-support test status
  • Form 990 / 990-EZ / 990-N filing threshold for current year
  • Sponsorship vs. advertising classification for any branded events

Other HSN entities