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The Tax Law of Private Foundations, 2021 Cumulative Supplement, 5th Edition

The Tax Law of Private Foundations: 2021 Cumulative Supplement

PrefaceBook Citations1 Introduction to Private Foundations
1.1 Private Foundations: Unique Organizations
1.2 Definition of Private Foundation
1.4 Private Foundation Law Primer
1.5 Foundations in Overall Exempt Organizations Context
1.6 Definition of Charity
1.7 Operating for Charitable Purposes
1.9 Private Foundation Sanctions
1.10 Statistical Profile
1.11 Private Foundations and Law 50 Years Later2 Starting, Funding, and Governing a Private Foundation
2.1 Choice of Organizational Form
2.3 Estate Planning Principles
2.4 Foundations and Planned Giving
2.5 Acquiring Recognition of Tax-Exempt Status
2.6 Special Requirements for Charitable Organizations
2.7 When to Report Back to the IRS3 Types of Private Foundations
3.1 Private Operating Foundations
3.3 Conduit Foundations
3.8 Split-Interest Trusts
3.9 Foreign Private Foundations4 Disqualified Persons
4.1 Substantial Contributors
4.2 Foundation Managers
4.3 Certain 20 Percent Owners
4.4 Family Members
4.5 Corporations or Partnerships
4.6 Trusts or Estates5 Self-Dealing
5.1 Private Inurement Doctrine
5.2 Private Benefit Doctrine
5.3 Definition of Self-Dealing
5.3A Excess Compensation Tax
5.4 Sale, Exchange, Lease, or Furnishing of Property
5.5 Loans and Other Extensions of Credit
5.6 Payment of Compensation
5.8 Uses of Income or Assets by Disqualified Persons
5.11 Indirect Self-Dealing
5.12 Property Held by Fiduciaries
5.14 Additional Exceptions
5.15 Issues Once Self-Dealing Occurs6 Mandatory Distributions
6.1 Distribution Requirements--in General
6.2 Assets Used to Calculate Minimum Investment Return
6.3 Determining Fair Market Value
6.5 Qualifying Distributions7 Excess Business Holdings
7.1 General Rules
7.2 Permitted and Excess Holdings
7.3 Functionally Related Businesses
7.7 Excise Taxes on Excess Holdings8 Jeopardizing Investments
8.2 Prudent Investments
8.3 Program-Related Investments9 Taxable Expenditures
9.1 Legislative Activities
9.2 Political Campaign Activities
9.3 Grants to Individuals
9.4 Grants to Public Charities
9.5A Funding of Employee Hardship Programs
9.6 Grants to Foreign Organizations
9.8 Internet and Private Foundations
9.9 Spending for Noncharitable Purposes
9.10A Distributions to Group Exemption Organizations
9.11 Excise Tax for Taxable Expenditures10 Tax on Investment Income
10.1 Rate of Tax
10.3 Formula for Taxable Income
10.5 Foreign Foundations11 Unrelated Business Activity
11.1 General Rules
11.2 Exceptions
11.3 Rules Specifically Applicable to Private Foundations
11.4 Unrelated Debt-Financed Income Rules
11.5 Calculating and Reporting the Tax12 Tax Compliance and Administrative Issues13 Termination of Foundation Status
13.1 Voluntary Termination
13.3 Transfer of Assets to a Public Charity
13.4 Operation as a Public Charity
13.6 Termination Tax14 Charitable Giving Rules
14.1 Concept of Gift
14.2 Basic Rules
14.4 Deductibility of Gifts to Foundations
14.5 Qualified Appreciated Stock Rule
14.8 Planned Giving Revisited
14.9 Administrative Considerations15 Private Foundations and Public Charities
15.2 Evolution of Law of Private Foundations
15.3 Organizations with Inherently Public Attributes
15.4 Publicly Supported Organizations--Donative Entities
15.5 Service Provider Organizations
15.7 Supporting Organizations
15.8 Change of Public Charity Category
15.9 Noncharitable Supported Organizations16 Donor-Advised Funds
16.1 Basic Definitions
16.3 Types of Donor Funds
16.7 Public Charity Status of Funds
16.9 Statutory Criteria
16.12 Tax Regulations
16.13 DAF Statistical Portrait
16.14 Criticisms and Commentary17 Corporate Foundations
17.2 Reasons for Establishment of a Corporate Foundation
17.3 Private Inurement Doctrine
17.3A Private Benefit Doctrine
17.5 Self-Dealing Rules
17.6 Other Private Foundations Rules
17.7 Tax on Excess Compensation: Potentially Applicable Exceptions IllustratedTable of CasesTable of IRS Revenue Rulings and Revenue ProceduresTable of IRS Private Determinations Cited in TextTable of IRS Private Letter Rulings, Technical Advice Memoranda, and General Counsel MemorandaAbout the AuthorAbout the Online ResourcesCumulative Index