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Private Letter Ruling Roundup Pre-1969 Foreign Private Foundation Can’t Qualify for Exemption Under IRC §501(c)(4).  


Author:  Staff Editors.


Source: Volume 08, Number 02, January/February 2009 , pp.13-14(2)




Family Foundation Advisor

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Abstract: 

Addressing an odd set of facts, the IRS held in Private Letter Ruling 200846041 that a foreign foundation formed before 1969 (and thus before the Tax Reform Act of 1969) did not qualify as a §501(c)(4) organization.

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