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IRS Ruling Illustrates Application of “Personal Service” Exception to Self-Dealing  


Author:  Katherine E. David.


Source: Volume 16, Number 01, November/December 2016 , pp.14-16(3)




Family Foundation Advisor

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Abstract: 

A private foundation is prohibited from making payments to a disqualified person, even if the payments reflect the fair market value of property or services the disqualified person provides to the foundation. PLR 201630009 provides a helpful example that professional and managerial services other than those types enumerated in the IRC §4941 regulations may constitute “personal services” for which a foundation can compensate a disqualified person.

Keywords: Compensation to Disqualified Person

Affiliations:  1: Strasburger & Price, LLP.

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