April 2022
Intermediate to advanced
208 pages
6h 6m
English
Content preview from Tax Planning and Compliance for Tax-Exempt Organizations, 6th Edition
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CHAPTER 14Self-Dealing: IRC § 4941
§ 14.2 Sale, Exchange, or Lease of Property
(d) Co-Owned Property
p. 382. Add to complete paragraph at top of page:
The IRS announced that it will not issue rulings on whether certain transactions are self-dealing when a private foundation and LLCs owned by disqualified persons are involved. This IRS action impacts what is referred to as the IRS “No-Rule List.”
p. 382. Add at the end of footnote 55:
Priv. Ltr. Ruls. 200116047 and 9238027.
p. 383. Add new bullet at top of page:
- A charitable lead trust held a nonvoting interest in an LLC along with disqualified persons. Investment in the LLC and continued ownership of interest in the LLC brought the CLT distributions from LLC of a proportionate share of payments on the note held by the LLC. Actions taken by the LLC in connection with enforcement and collection of the note were found not to constitute self-dealing.1
§ 14.5 Transactions That Benefit Disqualified Persons
p. 400. Add new bullet to list:
- A private foundation requested a ruling on the application of IRC §§ 4941, 4942, and 4945 to its grant program. The PF presents art exhibitions to support the work of unrecognized individual artists. A director of the Foundation individually purchased three works of art from Artist A, whose work had been displayed by an art gallery supported by the PF. The PF plans to ...
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