PFS10. Changes in Private Foundation Structure: Do NOT Do This Without a Net!

Field of Study: 
Taxes
CPE Credit: 
1.5
Knowledge Level: 
Overview
Advanced Preparation: 
None
Prerequisite: 
None

Friday, June 22, 2018
 
9:00AM-10:15AM

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.

Learning Objectives:

  • Recognize when §507 would apply if a foundation has a termination, reorganization or significant disposition of assets
  • Recall how to avoid potentially expensive errors