Home      Login

Abstract: 

Our review of Private Letter Rulings includes a reclassification based on an audit that found a charitable organization did not qualify as a “school” under IRC §170(b)(1)(A)(ii) but did retain its exemption because it sources of support and met the “publicly funded organization” requirements of IRC §170(b)(1)(A)(vi). In PLR 201909015 the IRS ruled that a grant that an organization would receive through a merger of its supporting organization with and into it would constitute an unusual grant. PLR 201851003 determined that a grant to assist a global religion journalism project met the conditions of a qualifying distribution and was not a taxable expenditure.

Keywords: Reclassifications of Public Charities’ Foundation Status; “Unusual Grants”; Qualifying Distributions

Affiliations:  1: Clark Hill Strasburger.