target="_blank" rel="nofollow" href="#ulink_3243539a-95d7-5185-ab47-121ab368eeba">476 Reg. § 1.509(a)-4(i)(4)(i)(B).477 477 Reg. § 1.509(a)-4(i)(4)(i)(C).
478 478 Reg. § 1.509(a)-4(i)(5)(i)(A).
479 479 Reg. §§ 1.509(a)-4(i)(5)(ii), 1.509(a)-4T(i)(5)(ii)(B).
480 480 Reg. §§ 1.509(a)-4(i)(5)(i)(B), 1.509(a)-4(i)(9).
481 481 Reg. § 1.509(a)-4(i)(6).
482 482 Reg. § 1.509(a)-4(i)(7).
483 483 Reg. § 1.509(a)-4(i)(8).
484 484 See Private Foundations ch. 7.
485 485 IRC § 4943(f)(1), 3(A).
486 486 See supra note 468.
487 487 IRC § 4943(f)(5)(B).
488 488 IRC § 4943(f)(1), 3(B).
489 489 IRC § 4943(f)(2).
490 490 See Private Foundations ch. 6.
491 491 IRC § 4942(g)(4). As to the second element of this rule, a payment also is not a qualifying distribution if the IRS determines by regulation that the distribution “otherwise is inappropriate” (IRC § 4942(g)(4)(ii)(II)).
492 492 IRC § 4945(d)(4). See Private Foundations ch. 9. A supporting organization that wishes to avoid these rules may make application to the IRS, pursuant to special procedures, to change its public charity status (Ann. 2006-93, 2006-48 I.R.B. 1017).
493 493 That is, organizations that are tax-exempt by reason of IRC § 501(c)(4). See Tax-Exempt Organizations ch. 13.
494 494 That is, organizations that are tax-exempt by reason of IRC § 501(c)(5). See Tax-Exempt Organizations ch. 16.
495 495 That is, organizations that are tax-exempt by reason of IRC § 501(c)(6). See Tax-Exempt Organizations ch. 14.
496 496 IRC § 509(a)(3), last sentence; Reg. § 1.509(a)-4(k).
497 497 IRC § 509(a)(3)(C); Reg. § 1.509(a)-4(a)(4). These rules are discussed in Tax-Exempt Organizations § 12.3(c).
498 498 Pension Protection Act of 2006, Pub. L. No. 109-280 § 1226.
499 499 That is, organizations that are described in IRC § 501(c)(3).
500 500 See § 5.6(a), text accompanied by note 53.
501 501 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(F)(i). This report is summarized in Private Foundations § 15.7(l). A subsequent report on supporting organizations issued by the Congressional Research Service is summarized in Private Foundations § 16.11.
502 502 IRC § 4942(j)(3). The rules concerning private operating foundations are discussed in Private Foundations § 3.1.
503 503 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(F)(ii).
504 504 See Private Foundations § 6.5.
505 505 The rules concerning conduit foundations are discussed in Private Foundations § 3.2. For this tax treatment to occur, the donee private foundation must make an election (Reg. § 1.170A-9(g)(2)(v)) to treat the qualifying distributions as distributions out of corpus, so as to substantiate the larger charitable deductions. In a situation in which the election was not made, because the foundation was unaware of it (despite the involvement of professional tax advisors), the IRS exercised its discretionary authority (Reg. § 301.9100-3) to grant an extension of time to make this election (Priv. Ltr. Rul. 200311033).
506 506 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(F)(iii).
507 507 The rules concerning common fund foundations are discussed in Private Foundations § 3.3.
508 508 That is, an organization described in IRC § 501(c)(3).
509 509 IRC §§ 511–514.
510 510 Reg. § 1.513-1(b).
511 511 The test is discussed in Tax-Exempt Organizations § 24.1.
512 512 United States v. American College of Physicians, 475 U.S. 834 (1986).
513 513 Reg. § 1.513-1(a).
514 514
