If the letters patent, trust deeds or by-laws of an entity indicate that anything more than a return of capital or taxable capital gains may be made available to members by way of dividend or otherwise, or the entity otherwise has the power in the current or future years to declare and pay dividends out of current or retained income, it will not qualify. If the balance of the accumulated excess is greater than the non-profit organization's reasonable needs to carry on its non-profit activities, RC will consider profit to be one of the purposes for which the organization was operated.