Private Foundations

CHAPTER FIFTEENPrivate Foundations and Public Charities

1. *§ 15.4 Publicly Supported Organizations Donative Entities
   1. (a) General Rules
2. § 15.5 Service Provider Organizations
   1. *(c) Unusual Grants
3. § 15.7 Supporting Organizations
   1. (g) Operated in Connection with (Type III)
4. § 15.8 Change of Public Charity Category
   1. (b) From § 509(a)(3) to § 509(a)(1) or 509(a)(2)
   2. (d) IRS Recognition of Change in Status

*§ 15.4 PUBLICLY SUPPORTED ORGANIZATIONS DONATIVE ENTITIES

(a) General Rules

p. 730, note 95. Delete and substitute:

Reg. § 1,170A-9(f)(6)(v). This concept of earmarking is also reflected in the rules for service provider organizations (see § 15.5) (Reg. § 1.509(a)-3(j)(1), (2). Examples that apply in both contexts are in Reg. § 1.509(a)-3(j)(3).

§ 15.5 SERVICE PROVIDER ORGANIZATIONS

(c) Unusual Grants

p. 749, note 181, first line. Delete Reg. citation and substitute:

Reg. § 1.509(a)-3(c)(3), (4).

p. 749, note 181, second line. Delete Reg. citation and substitute:

Reg. § 170A-9(f)(6)(ii), (iii).

p. 750. Insert as first complete paragraph:

There has been a flurry of favorable private letter rulings concerning unusual grants this spring. In one instance, a community foundation was about to receive a bequest from an estate, the size of which was unusual compared with the foundation's support levels and which would have adversely affected its status as a public charity; the decedent had not previously contributed a substantial part of the foundation's support and the bequest ...