Private Foundations

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4 Takeaways from Council on Foundations 2016 Annual Conference

From April 9 to April 12, I had the good fortune to be part of the Council on Foundations 2016 Annual Conference. The Council welcomed nearly 1,400 leaders in the philanthropic sector to Washington, D.C., for plenary programs...more

Program Related Investments: Final Regulations

Final Regulations Highlight the Broad Range of Available PRI Purposes, Recipients and Financial Structures - Final program related investment (PRI) regulations released and effective on April 25, 2016 illustrate the...more

Treasury Releases Final Program-Related Investment Regulations – Installment # 1

Treasury has released Final Regulations under Section 4944 of the Code providing additional guidance regarding program related investments (“PRIs”). Technically, a PRI is an investment by a private foundation (1) the primary...more

New Regulations Expand Opportunities for Program-Related Investments

In recently released final regulations, the IRS and the Department of the Treasury have provided additional examples of investments that qualify as program-related investments (“PRIs”) for private foundations. The final...more

Breaking News: PRI Examples Are Finalized, with Improvements

Yesterday, Treasury and the Internal Revenue Service (IRS) finalized the regulations describing nine new program-related investment (PRI) examples that were first proposed on April 19, 2012. The final regulations incorporate...more

Corporate Tax Reform Proposal Would Raise Taxes on Exempts

Legislation could impose new taxes on dividend and interest income of tax-exempt entities. The Senate Finance Committee is reportedly formulating a legislative proposal to integrate the corporate and individual tax...more

Treasury Green Book Proposals — Charitable Contribution Deduction Limitations

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

Treasury Green Book Proposals — Private Foundations

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

Sale of LIHTC Project Does Not Generate UBTI or Excess Business Holdings

The IRS recently ruled that a private foundation’s proposed acquisition of 100% of a low-income housing project would not subject the foundation to either excess business holdings tax or unrelated business income tax. See PLR...more

Provisions Affecting Charities in Proposed Budget

The Administration’s proposed budget for Fiscal Year 2017 features several proposals that would impact charitable organizations and their donors, including proposals to streamline the private foundation excise tax on net...more

Federal Tax Advisory: Private Foundations and Lobbying

The Tax Court mostly ruled against a private foundation and its main contributor and foundation manager by approving the assessment of the private foundation excise tax on lobbying expenditures. However, the court gave them a...more

Will 2015 IRS Notice Boost Foundations’ Mission-Related Investing in 2016?

Foundations are effective vehicles for families who want to make a collective philanthropic impact now and for generations to come. Traditionally, foundations have achieved this impact solely through strategic grantmaking. A...more

Keeping it Together: Foundations, DAFs, and the Problem of Bifurcated Payments

The end of the year brings a flood of gifts and grants to public charities, as well as perennial questions about how the donor will benefit in return. As a general matter, individual donors may receive “benefits” in...more

Charities and Mission Investing

Private foundations, community foundations, and other public charities and nonprofit organizations are seeking different, and sometimes innovative, ways to further their charitable purposes. One area receiving increasing...more

The Debate Intensifies on the Best Strategy to Recover Foreign Securities Losses

Recent doubts have been raised as to the effectiveness of Dutch Foundations, which have become an important vehicle in foreign recoveries. While Dutch Foundations have negotiated settlements in some situations, some foreign...more

Private Foundation Can Limit Grant Scholarships to Students Attending Specific Schools

A private foundation that makes a grant to an individual for travel, study, or other similar purposes makes a “taxable expenditure” that is subject to a penalty excise tax under Code Section 4945. However, if the grant is...more

IRS Encourages Private Foundations to Consider Charitable Purposes in Investing Its Assets

As we previously reported, the IRS has updated its guidance with helpful examples concerning program-related investments for private foundations. In its recently issued Notice 2015-62, the IRS provides further assurance that...more

Contributions of Art: Elements of a “Boring” Charitable Contribution Deduction

This article highlights some of the more critical income tax issues that taxpayers and their advisors must address when claiming the charitable contribution deduction for the gift of art to art museums. This article does not...more

IRS Publishes Final Regulations for Equivalency Determinations

Take note of these practical concerns for private foundations making grants to foreign organizations. On September 25, the Internal Revenue Service (IRS) published final regulations for private foundations making good...more

IRS Blesses Private Foundation Mission-Related Investing: Implications for the Charitable Sector

The IRS has formally confirmed that private foundations may make investments that further their charitable purposes even when those investments do not qualify as permitted program-related investments (“PRIs”) under the...more

IRS Provides Guidance on Mission-Related Investments by Private Foundations

New guidance permits private foundations to consider charitable purposes when making investments with a substantial purpose of capital appreciation or the production of income....more

Private Foundations: A Brief Overview of Rules and Practical Steps for Grant-Making

Private Foundation Rules to Remember - Private foundations must follow a variety of rules to avoid the imposition of potentially onerous penalty taxes on the foundation and its related parties...more

Ray Charles Foundation v. Robinson - USCA, Ninth Circuit, July 31, 2015

Ninth Circuit reverses lower court’s dismissal for lack of standing of action brought by Ray Charles Foundation, finding that Foundation, sole beneficiary of music legend’s estate, had standing to challenge validity of...more

China Issues Draft Legislation to Strengthen Regulation over Foreign NGOs

Nonprofit and nongovernmental organizations in the PRC (NGOs), both domestic and foreign, have played important roles in China’s economic and social development over the years. While the number of foreign NGOs conducting...more

Trends, Pitfalls and Opportunities in Celebrity Philanthropy

Athletes and celebrities have a long and storied track record with charitable causes. A celebrity can turn an otherwise unknown cause into a charitable powerhouse simply by lending a high profile name and likeness. Today,...more

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