FLPs and Private Foundations: The Good, the Bad, and the Ugly
Author: Douglas W. Stein.
Source: Volume 07, Number 01, November/December 2007 , pp.3-5(3)
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Abstract:
Many taxpayers have family limited partnership (FLP) interests they wish to donate to their private foundations. While FLPs are complicated structures by themselves, when mixed with charity numerous new issues are raised of which many practitioners are simply unaware. These additional issues stem from the private foundation rules of chapter 42 of the Internal Revenue Code (IRC) and include such issues as self-dealing, excess business holdings, and private benefit transactions.Keywords:
Affiliations:
1: Barris, Sott, Denn & Driker, PLLC.