The Tax Law of Private Foundations, 5th Edition

CHAPTER FIFTEENPrivate Foundations and Public Charities

• § 15.2 Evolution of Law of Private Foundations
• § 15.3 Organizations with Inherently Public Activity
  • (a) Churches and Similar Entities
  • (b) Educational Institutions
  • (c) Hospitals
  • (d) Medical Research Organizations
  • (f) Public College Support Foundations
  • (g) Governmental Units
• § 15.4 Publicly Supported Organizations—Donative Entities
  • (a) General Rules
  • (b) Support Test
  • (c) Facts and Circumstances Test
  • (d) Community Foundations
• § 15.5 Service Provider Organizations
  • (a) Investment Income Test
  • (c) Unusual Grants
• § 15.7 Supporting Organizations
  • (g) Operated in Connection with (Type III)
• § 15.8 Change of Public Charity Category
  • (a) From § 509(a)(1) to § 509(a)(2) or Vice Versa
  • (b) From § 509(a)(3) to § 509(a)(1) or § 509(a)(2)
  • (d) IRS Recognition of Change in Status
• § 15.9 Noncharitable Supported Organizations

§ 15.2 EVOLUTION OF LAW OF PRIVATE FOUNDATIONS

p. 626, note 28. Insert before period:

; Rev. Proc. 2020-5, 2020-1 I.R.B. 241 § 7.03

§ 15.3 ORGANIZATIONS WITH INHERENTLY PUBLIC ACTIVITY

(a) Churches and Similar Entities

p. 627, note 32, first line. Delete 1.170A-9(a) and insert 1.170A-9(b).

(b) Educational Institutions

p. 628, note 42, first line. Delete 1.170A-9(b) and insert 1.170A-9(c).

p. 629. Insert as last paragraph:

A court upended the foregoing requirements for qualification as an educational institution (and most of the other categories of public institutions), holding that the primary-function test ...