April 2020
Intermediate to advanced
944 pages
33h 53m
English
Content preview from Tax Planning and Compliance for Tax-Exempt Organizations, 6th Edition
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CHAPTER 12Private Foundations—General Concepts
- 12.1 Why Private Foundations Are Special
- 12.2 Special Rules Pertaining to Private Foundations
- 12.3 Application of Taxes to Certain Nonexempt Trusts
- 12.4 Termination of Private Foundation Status
- (a) Involuntary Termination
- (b) Voluntary Terminations
- (c) Transfer of Assets to a Public Charity
- (d) Conversion of Private Foundation into a Public Charity
- (e) Mergers, Split-Ups, and Transfers Between Foundations
- (f) Conversion to a Taxable Entity
- (g) Conversion of Public Charity to Private Foundation
- (h) Notifying the IRS
- APPENDIX 12-1: Brief Description of Tax Sanctions Applicable to Private Foundations
12.1 Why Private Foundations Are Special
Private foundations were segregated by Congress in 1969 from public charities—the latter being those organizations that traditionally receive their contributions from a wide range of supporters, rather than from a limited set of individuals. In the exempt organization community and throughout this book, private foundations are sometimes referred to as PFs. The persons who create, contribute to, and manage PFs are “disqualified persons” sometimes referred to as DPs.
Private foundations are viable and valuable types of nonprofit organizations, and the rules applicable to them warrant the six chapters.1 A PF is often the best tool to accomplish an individual's philanthropic goals. Unfortunately, some ...
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