Tax Planning and Compliance for Tax-Exempt Organizations, Fifth Edition 2019 Cumulative Supplement, 5th Edition
by Jody Blazek
CHAPTER 12Private Foundations—General Concepts
§ 12.2 Special Rules Pertaining to Private Foundations
(a) Types of Private Foundations
p. 280. Add to footnote 18:
Also see § 15.4(b) and § 53.4942(a)‐3(c)(2)(iv).
(c) Definition of Special Terms
p. 282. Add after second sentence in Substantial Contributor paragraph:
For self‐dealing purposes only, this term does not include any charitable organization including a private foundation.1
*p. 284. Add to Family Members paragraph:
Conversion of a nongrantor trust to a grantor trust was not considered a transfer of property subject to self‐dealing rules.2
p. 284. Add to Other Disqualified Persons paragraph:
The self‐dealing prohibition extends to transactions or other arrangements between a corporate foundation and the for‐profit business that is related to it, except the positive public recognition accorded a for‐profit company due to the charitable activities of its corporate foundation is not the type of private benefit that is a transgression of the self‐dealing rules.
The directors and officers of a for‐profit organization that control a corporate foundation are ...