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Private Letter Rulings  


Author:  Staff Editors.


Source: Volume 07, Number 05, July/August 2008 , pp.14-14(1)




Family Foundation Advisor

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Abstract: 

Should these organizations be treated as charitable in their own right, because they facilitate the work of their beneficiary charities? No Excise Tax on Foreign Foundation’s U.S.-Source Investment Income. In Technical Advice Memorandum 200817037, the IRS considered the situation of a foreign foundation that had the bulk of its endowment invested in U.S. investments.Organization Facilitating Real Estate Donations to Colleges Is Not a Charity.

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