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Changing a Foundation’s Status Without Changing Its IRC §501(c)(3) Status  


Author:  Katherine E. David, J.D..


Source: Volume 19, Number 06, September/October 2020 , pp.15-15(1)




Family Foundation Advisor

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Abstract: 

In accordance with IRC §509, IRC §501(c)(3), organizations are further classified as private foundations or public charities. This article analyzes three recent private letter rulings that modify the subject organization’s private foundation status without changing its IRC §501(c)(3) status—a change from IRC §509(a)(2) to IRC §509(a)(1) and IRC §170(b)(1)(A)(vi); from hospital to governmental unit; and from IRC §509(a)(2) organization to private foundation.

Keywords: IRS approval of reclassification of foundations and public charities; private letter rulings

Affiliations:  1: Clark Hill PLC.

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