Private foundations are NOT like public charities in one major way. Private foundations are subject to the IRC §507 termination tax. Never heard of it? Come to this session! A private foundation that liquidates, merges, or otherwise reorganizes itself with another public or private charitable entity is not treated as a newly created organization. This session will explore the benefits and consequences of the rule permiting or disallowing carryover of both favorable and unfavorable tax attributes. A termination caused by willful and flagrant repeated violations of the private foundation's sanctions results in a penalty of 100% or more of prior tax benefits.