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Abstract: 

Private foundations are required to distribute a minimum amount annually for charitable, religious, educational, or other tax-exempt purposes. However, contributions to certain public charities classified as “non-functionally integrated Type III supporting organizations” are not considered qualifying distributions and do not count toward a foundation’s minimum distribution. This article explains the characterization and treatment of such contributions and offers strategies for avoiding the unexpected tax liability, including excise taxes, that can arise from contributions to these entities.

Keywords: IRC §4945; IRS Business Master File

Affiliations:  1: Strasburger & Price, LLP.