Minimum Distribution Requirements: IRC § 4942
§ 15.1 Assets Used to Calculate Minimum Investment Return
(c) Exempt Function Assets
*p. 390. Add examples of functionally related business after last paragraph:
An artist left his for-profit corporation in which he operated his “artistic enterprise” to a private operating foundation (POF). The corporation had managed the artist's business, handling fabrication, shipment, sale, reproduction, and licensing of the work. Upon the transfer to the POF, the corporation changed its activities to a curatorial focus to foster an understanding of the broad scope of the artist's work, advance scholarship of his work, and manage the artist's legacy. The value of the corporation was excluded from MIR calculation as a functionally related asset.1
A private foundation owned a sheep ranch, and conducted educational research and development programs intended to enhance the quality and increase the production of range sheep in the western United States. The PF sought to develop and introduce into the market sheep with genetically desirable traits and further educational and ...