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Transfers Between Private FoundationsTransfers Between Private Foundations

At some point in the life of a private foundation (PF), it may be advantageous to transfer most or all of its assets to one or more other PFs. The most common reasons are to enable a PF's board members with incompatible objectives to pursue their interests independently and to achieve administrative efficiencies and a possible reduction in operating expenses by changing the PF's structure (trust vs.

24 Min Read
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Jeffrey D. Haskell, senior vice president, tax and legal affairs, Foundation Source, Fairfield, C

At some point in the life of a private foundation (PF), it may be advantageous to transfer most or all of its assets to one or more other PFs. The most common reasons are to enable a PF's board members with incompatible objectives to pursue their interests independently and to achieve administrative efficiencies and a possible reduction in operating expenses by changing the PF's structure (trust vs. corporation) or domicile.

The Internal Revenue Service requires a PF to comply with a multitude of constraints on its activities to maintain its tax-exempt status as an Internal Revenue Code Section 501(c)(3) organization. It's therefore unsurprisi...

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