The Tax Law of Private Foundations, 5th Edition

CHAPTER ONEIntroduction to Private Foundations

1. § 1.1 Private Foundations: Unique Organizations
2. § 1.2 Definition of Private Foundation
3. § 1.7 Operating for Charitable Purposes
4. § 1.9 Private Foundation Sanctions
   1. (a) Sanctions (a Reprise)
   2. (b) Self-Dealing Sanctions as Pigouvian Taxes
   3. (c) Self-Dealing Sanctions: Taxes or Penalties?
   4. (d) Abatement
5. § 1.10 Statistical Profile

§ 1.1 PRIVATE FOUNDATIONS: UNIQUE ORGANIZATIONS

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over 1.5 million¹

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§ 1.2 DEFINITION OF PRIVATE FOUNDATION

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; IRS Revenue Procedure (Rev. Proc.) 2020-5, 2020-1 I.R.B. 241, § 7.03

§ 1.7 OPERATING FOR CHARITABLE PURPOSES

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^88.1Reg. § 1.501(c)(3)-1(c)(1).

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A private foundation has its tax-exempt status revoked for failing to engage in any exempt activities over a long period of time (Community Education Foundation v. Commissioner, 112 T.C.M. 637 (2016), appeal denied because of lack of representation (__ F.3d __ (D.C. Cir. 2018))).

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In general, Tax-Exempt Organizations § 4.4.

§ 1.9 PRIVATE FOUNDATION SANCTIONS

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