Community Foundations Providing Services to Family Foundations May Realize Unrelated Business Income
Author: Staff Editors.
Source: Volume 08, Number 02, January/February 2009 , pp.3-3(1)
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Abstract:
One function of the typical community foundation is to encourage and support charitable activities in the community it serves. This often involves helping local family foundations with their own charitable activities. Surprisingly, in Private Letter Rulings 200832027 and 200832028, the IRS held that income from the provision of grantmaking assistance to such unrelated foundations would not produce unrelated business income (UBI), but revenue from administrative, clerical, legal, and computer services would produce UBI despite a close relationship to grant-making activities.Keywords:
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