Recent Private Letter Rulings of Interest
Author: Katherine E. David.
Source: Volume 14, Number 02, January/February 2015 , pp.13-16(4)
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Abstract:
In recent PLRs, the IRS ruled that a private foundation’s distributions would not adversely affect or jeopardize its tax-exempt status; that the storage of two disqualified person’s works of art loaned to a private foundation would not constitute self-dealing; that because the private foundation will receive the LLC interests pursuant to a bequest, the location of the LLC property next to disqualified persons’ property is not of the private foundation’s choosing.Keywords: Qualifying Distributions Under IRC §4942; Self-Dealing Under IRC §4941; Transfers of Assets Between Foundations
Affiliations:
1: Strasburger & Price, LLP.