- § 17.1 Corporate Foundation Overview
- § 17.2 Reasons for Establishment of a Corporate Foundation
- § 17.3 Private Inurement Doctrine
- § 17.4 Disqualified Persons Rules
- § 17.5 Self-Dealing Rules
- § 17.6 Other Private Foundations Rules
Tax-exempt charitable organizations that are affiliated with for-profit corporations, and usually controlled by them, are almost always private foundations (generically, corporate foundations). This private foundation status arises, in large part, because the related for-profit corporation typically is the sole funder of the corporate foundation.
§ 17.1 Corporate Foundation Overview
Among the four features of a conventional private foundation is the characteristic that it is funded from one source.2 Because the typical foundation related to a for-profit business is financially supported only by that business entity, the corporate foundation usually is a private foundation. It is possible for a charitable organization that is controlled by a for-profit entity to be a public charity—most likely, a donative-type publicly supported organization3—but these ...