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IRS Provides Safe Harbor for Equivalency Determination Written Advice  


Author:  Katherine E. David.


Source: Volume 17, Number 01, November/December 2017 , pp.1-6(6)




Family Foundation Advisor

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Abstract: 

The IRS has issued anticipated guidance for qualified tax practitioners to use in preparing written advice on which a private foundation may rely for purposes of making an equivalency determination that a foreign grantee is equivalent to a public charity. This article examines the main provisions and implications of Rev. Proc. 2017-53, which provides a safe harbor under which written advice from a “qualified tax practitioner” will be considered to contain sufficient facts.

Keywords: Rev. Proc. 2017-53; Grants to Foreign Organizations; Organization-Specific Requirements; Reliance Period

Affiliations:  1: Strasburger & Price, LLP.

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