Public Charity or Private Foundation Status Issues under IRC 509(a)(1)-(4), 4942(j)(3), and 507

Richardson, Virginia G.; Reilly, John Francis
May 2012
How to Form a Nonprofit Corporation (9781413313871);May2012, pF7
The article presents an overview of the issues confronted when dealing with whether an organization is a public charity or a private foundation, whether it is a private operating foundation, and what are the rules about termination of private foundation status in California. It discusses the Tax Reform Act of 1969 which is based on the distinction between private foundations and public charities. Details on the expenditure responsibility rules of the Internal Revenue Code are shown.


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