Recent Private Letter Rulings of Interest
Author: Katherine E. David.
Source: Volume 15, Number 03, March/April 2016 , pp.15-16(2)
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Abstract:
Recent PLRs include a ruling that a foundation that had acquired an LLC operating an affordable housing project qualifies as §501(c)(3) activity; the revocation of a private foundation’s exempt status for private inurement and failure to distribute income; and a ruling that transfers of assets to recipient private foundations does not trigger the usual termination tax on a foundation closing its doors.Keywords: Foundation acquisition of LLC; foundation termination; self-dealing
Affiliations:
1: Strasburger & Price, LLP.