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Abstract: 

By far the most common family foundation issues presented to the IRS in ruling requests are those arising under IRC § 4941, the prohibition on self-dealing. A recent example is PLR 200352021,which held that a complicated arrangement among a family foundation, a family-owned bank, and a family office would not give rise to a self-dealing violation. The facts are obscured, as usual with such private letter rulings, but here is a summary.

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