Oct 1, 2008 12:00 PM

Tax Boundaries For Community Foundations

With the rise of the commercial donor-advised funds (DAFs) during the past decade, traditional community foundations have sought to remain relevant by offering extra services to local donors and charitable organizations. A recent private letter ruling sets the parameters for what services community foundations can offer to local private foundations for a fee — without incurring unrelated business income tax (UBIT).

In PLR 200832027, issued Aug. 8, 2008, a community foundation sought to provide, for a fee, a broad menu of back office services to private foundations located in the same locality, including help with grant making, grant administration and general clerical work. The Service ruled that fees received for services directly related to grant-making activities would not be subject to tax as the community foundation's unrelated business income (UBI).

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