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)
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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.