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 16Excess Business Holdings and Jeopardizing Investments: IRC §§ 4943 and 4944
§ 16.1 Excess Business Holdings
(d) Constructive Ownership
p. 477. Add to footnote 33 as the second sentence:
The managers of a revocable trust holding a note receivable formed an LLC with both voting and nonvoting interests. The nonvoting interests were transferred to a CLT, the beneficiary of which is a private foundation. The CLT's interest will be not counted for purposes of the excess business rules.
(e) Disposition Periods
p. 478. Add at end of Five-Year Period paragraph:
Disposition for stock holdings received through a bequest and trust distributions once a major donor died was extended by the IRS. Significant efforts had been made, and were continuing, to try to dispose of the shares that left the foundation with more than the permissible 2 percent of the outstanding shares. The foundation had obtained periodic reviews by an attorney to assess the marketability of its shares in the Company and hired an experienced investment banking firm to broaden its search for outside investors. The taxpayer represented that it has been engaging in productive discussions with the Company since the beginning of the current year. The taxpayer states that the Company has expressed an interest in redeeming the shares of all shareholders and a willingness to provide financial and ...
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