Some public charities lose their tax-exempt status for failure to meet ongoing public support tests over a moving 5-year window.1 If such a public charity fails to meet the applicable support test for two consecutive years, Treasury regulations provide that it be treated as a private foundation (PF)—but only for certain purposes—as of the beginning of that second consecutive year (the “transition year”). Of course, a public charity may not know if it will fail the public
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