Recent Private Letter Rulings of Interest
Author: Katherine E. David.
Source: Volume 16, Number 05, July/August 2017 , pp.14-16(3)
< previous article |next article > |return to table of contents
Abstract:
In our regular survey of PLRs affecting family foundations, Katherine David reviews rulings that to qualify for exemption, organizations must serve public, not private interest: in one ruling, the service ruled that because selection criteria were tailored to apply only to founders’ son, a scholarship organization does not qualify for exemption; in another, the IRS ruled that a lymphoma support organization served a private interest and therefor did not qualify for tax exemption. In letters on unrelated business questions, the service ruled that revenue from technical services activity not unrelated business taxable income; and that a foundation’s operation of a coffee shop does not give rise to unrelated business income and that associated expenses are qualifying distributions. We also report on private letter rulings concerning self-dealing from youth program participants’ service to a for-profit company.Keywords: Unrelated business income; self-dealing; public v. private interest
Affiliations:
1: Strasburger & Price, LLP.