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Abstract: 

In late September, the IRS issued final regulations regarding reliance standards for private foundations seeking to make a good-faith determination that a foreign organization is a charitable organization that is not a private foundation. This article examines changes foundations will have to make under the new rules, specifically with respect to the use of an affidavit from a foreign grantee as an information source for making a good-faith determination, which no longer can be relied upon as the basis for the determination.

Keywords: Rev. Proc. 92-94; qualifying distributions; equivalency determinations

Affiliations:  1: Strasburger & Price, LLP.