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Abstract: 

Although private letter rulings are not regarded as binding authority, they often do provide readers with insight into what new ideas might be worth considering for their own donors and clients. In the rulings in this issue the question of self-dealing arises when an LLC rents property to a foundation; a foundation seeks to set aside funds for a large future project and to treat the set-aside amount as a qualifying distribution for the year; the IRS holds that nonvoting shares of a corporation held by a private foundation are permitted holdings—not excess business holdings under Code §4943; The IRS rules that the grant-making program through which American art is brought to international audiences meets the requirements of §4945(g)(3) and that the grants will not constitute taxable expenditures; the issue of whether a ranch is used (or held for use) directly in carrying out a private foundation’s exempt purpose such that its value can be excluded from the calculation of the private foundation’s annual minimum distribution requirement; and in the last ruling reviewed the IRS considers whether a private operating foundation’s sales of interests in condominium property would generate UBTI or adversely affect its tax-exempt status.

Keywords: PLR 201301015; PLR 201321028; PLR 201302044; PLR 201302044; PLR 201307010; PLR 201307011; PLR 201307012; PLR 201303021; PLR 201318008; PLR 201319032; PLR 201319033; PLR 201317019; PLR 201304010; PLR 201306025; PLR 201308031; PLR 201315031; PLR 20130

Affiliations:  .