Private Foundations: Tax Law and Compliance, 4th Edition

Chapter FifteenPrivate Foundations and Public Charities

1. § 15.1 Distinctions Between Public and Private Charities
2. § 15.2 Evolution of Law of Private Foundations
3. § 15.3 Organizations with Inherently Public Activity
   1. (a) Churches and Similar Entities
   2. (b) Educational Institutions
   3. (c) Hospitals and Other Medical Organizations
   4. (d) Public College Support Foundations
   5. (e) Governmental Units
4. § 15.4 Publicly Supported Organizations—Donative Entities
   1. (a) General Rules
   2. (b) Support Test
   3. (c) Facts and Circumstances Test
   4. (d) Community Foundations
   5. (e) Community Foundation Compliance Check Project
5. § 15.5 Service Provider Organizations
   1. (a) Investment Income Test
   2. (b) Concept of Normally
   3. (c) Unusual Grants
   4. (d) Limitations on Support
6. § 15.6 Comparative Analysis of the two Categories of Publicly Supported Charities
   1. (a) Definition of Support
   2. (b) Major Gifts and Grants
   3. (c) Types of Support
7. § 15.7 Supporting Organizations
   1. (a) Organizational Test
   2. (b) Operational Test
   3. (c) Specified Public Charities
   4. (d) Required Relationships
   5. (e) Operated, Supervised, or Controlled by (Type I)
   6. (f) Supervised or Controlled in Connection with (Type II)
   7. (g) Operated in Connection with (Type III)
   8. (h) Application of Excess Benefit Transactions Rules
   9. (i) Limitation on Control
   10. (j) Hospital and Other Reorganizations
   11. (k) Use of For-Profit Subsidiaries
   12. (l) Department of Treasury Study
   13. (m) IRS Ruling Policy
8. § 15.8 Change of Public Charity Category
   1. (a) From § 509(a)(1) to § 509(a)(2) or Vice Versa
   2. (b) From § 509(a)(3) to ...