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May 1, 2007 12:00 PM
Transfers 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. 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 unsurprising that a significant transfer of assets between PFs — referred to as a “507(b)(2) transfer” — also has complex rules. Here's a guide.
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Topics of Interest
| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
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Topics of Interest
| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
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