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Abstract: 

During the Fall Joint Meeting of the ABA Section of Real Property Trust and Estate Law and the ABA Section of Taxation, Attorney Mark B. Weinberg offered the participants a useful Affidavit form for qualifying an overseas potential grantee to receive funds from either a U.S. private foundation or a public charity. Based on a completed affidavit of this sort, knowledgeable counsel can determine whether the foreign organization is equivalent to a U.S. public charity so a private foundation can make grants to it without incurring excise tax for a taxable expenditure under Code §4945.

Keywords: Foreign Grantee Equivalence Affidavit; IRC §4945

Affiliations:  1: Jacobs & Tolani, LLP.