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Abstract: 

Our review of Private Letter Rulings includes PLR 201829003, in which the IRS determined that a private operating foundation could exclude a tract of undeveloped land (“Land”) from the calculation of its minimum investment return, because the foundation used the Land directly in carrying out its exempt purpose. In PLRs 201833027, 201835013, and 201848018the IRS approved foundations’ requests to set-aside funds for construction of an arts campus facility, visitors’ center, and a private boarding school, respectively, while in 201835014 the service denied a set-aside the foundation had sought while litigation over the replacement of its charitable beneficiary was pending.

Keywords: Computation of Minimum Investment Return; Qualifying Distributions

Affiliations:  1: Family Foundation Advisor.