Private Foundations

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Charitable Planning with S Corporation Stock—Making It Work

Since 1998, charities have been able to own S corporation stock (“S stock”). However, the ownership of S stock by an exempt organization may result in either an unexpected tax burden or a liability rather than an asset for...more

Is It a Violation to Help?

In a May 21, 2014, letter to the President of the American Hospital Association (AHA), U.S. Department of Health and Human Services (HHS) Secretary Kathleen Sebelius confirmed HHS’s position that private, not-for-profit...more

The charitable corporation: A trust in disguise?

The charitable trust can have certain practical advantages over the charitable corporation, at least in some quarters and under certain circumstances. Operational simplicity and low-cost maintenance are some of the pluses....more

Charitable Lead Trusts With Private Foundation Lead Beneficiary

Transfers to charitable lead trusts during lifetime can provide tax benefits to the donor, and can avoid inclusion of the transferred property in the gross estate of the donor for federal estate tax purposes at death....more

Is it a Private Foundation in the Eyes of the IRS?

The Internal Revenue Service ("IRS") recently held in Private Letter Ruling 201323035 that a corporation that was established as a nonprofit corporation under state law should not be granted tax exempt status because its...more

Consider a Private Foundation to Fulfill Your Philanthropic Goals

There are a variety of vehicles through which individuals and families can promote their charitable giving goals, and private foundations are often a leading choice. Simply stated, a private foundation is a type of charitable...more

A Full Plate for the IRS: IRS Releases 2012 Exempt Organizations 2012 Annual Report and 2013 Workplan

At the end of January, 2013, the IRS Exempt Organizations Group (“EO”) released its annual report, highlighting EO’s 2012 accomplishments and outlining its priorities for 2013. This year’s report was significantly more...more

IRS Issues Regulations for Type III Supporting Organizations

Type III supporting organizations should take steps to comply with new regulations and funders should review due diligence procedures for grants made to these organizations. On December 21, 2012, the Internal Revenue...more

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