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Abstract: 

The IRS rules that a loan of property from a trust to a private operating foundation and related transactions would not constitute self dealing, even though the foundation bore the costs of transportation and other expenses related to the artifacts. Another recent IRS private letter ruling is instructive for family foundations considering exceptionally large gifts to public charities, where the size of the gift could cause the recipient to fail its public support test. Two identical private letter rulings are instructive to private foundations (and split-interest trusts treated as private foundations) that make terminating distributions to other private foundations.

Keywords: PLR 201346011; PLR 201342011; PLR 201345033; PLR 201345034

Affiliations:  1: Strasburger & Price, LLP.