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


(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).


(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 ...

Get Private Foundations now with the O’Reilly learning platform.

O’Reilly members experience books, live events, courses curated by job role, and more from O’Reilly and nearly 200 top publishers.