The Tax Law of Private Foundations, 5th Edition

CHAPTER FIVESelf-Dealing

1. § 5.1 Private Inurement Doctrine
2. § 5.2 Private Benefit Doctrine
3. § 5.3 Definition of Self-Dealing
   1. (a) Six Acts
   2. (b) Statutory Exceptions
   3. (c) Exceptions Provided in Regulations
4. § 5.3A Excess Compensation Tax
5. § 5.4 Sale, Exchange, Lease, or Furnishing of Property
   1. (a) Sales
   2. (b) Exchanges
6. § 5.5 Loans and Other Extensions of Credit
7. § 5.6 Payment of Compensation
   1. (a) Definition of Personal Services
   2. (b) Definition of Compensation
   3. (c) Definition of Reasonable
8. § 5.8 Uses of Income or Assets by Disqualified Persons
   1. (c) For the Benefit of Transactions
9. § 5.11 Indirect Self-Dealing
   1. (a) Transactions with Controlled Entities
   2. (b) Concept of Control
   3. (c) Transactions and the Control Element
   4. (d) Exceptions
   5. (e) Representative Case (Reprise)
   6. (f) Fraudulent Investment Schemes
10. § 5.12 Property Held by Fiduciaries
    1. (a) Concept of the Expectancy
    2. (b) General Rules
    3. (c) Estate Administration Exception
    4. (d) Determining Fair Market Value
11. § 5.14 Additional Exceptions
    1. (a) Certain Corporate Organizations or Reorganizations
    2. (b) Other Exceptions
12. § 5.15 Issues Once Self-Dealing Occurs
    1. (a) Undoing the Transaction
    2. (b) Amount Involved
    3. (f) Abatement

§ 5.1 PRIVATE INUREMENT DOCTRINE

p. 138, first complete paragraph, sixth line. Insert footnote 12.1 following period:

^12.1An organization was denied recognition of exemption as a charitable entity in part because it issued voting stock providing equity interests to its shareholders, which the IRS found to be a violation of the private inurement ...