Private Letter Rulings More Set-Asides Approved—Who Says the IRS Is Hard to Get Along With?
Author: Staff Editors.
Source: Volume 05, Number 06, September/October 2006 , pp.14-14(1)
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Abstract:
To avoid the penalty tax, a foundation must make qualifying distributions each taxable year. Sometimes that is difficult, so a special rule permits a foundation to “set aside” grant funds under some circumstances and still be treated as having distributed these amounts for purposes of §4942. One way for a foundation to do this is to get a PLR from the IRS National Office approving the project in question as one that “can better be accomplished by such setaside than by immediate payment of funds.”Keywords:
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