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Abstract: 

In recent private letter rulings, the IRS ruled that a private operating foundation’s use of equipment and property and its involvement in property and employee-leasing transactions would not constitute acts of self-dealing. It also ruled that private foundation’s matching gifts program, through which the foundation matched charitable gifts made by employees of the foundation’s corporate sole contributor, did not give rise to acts of self-dealing or taxable expenditures, and that the matching gifts were qualifying distributions. In a third opinion, the service ruled that a foundation could exclude the value of leased land for purposes of calculating its annual required minimum distribution.

Keywords: PLR 201415010; PLR 201417022; PLR 201419017

Affiliations:  1: Strasburger & Price, LLP.