Excess business holdings and taxable expenditures of transferee private foundation: Section 507(b)(2) transfer


Whenever a private foundation makes a sec­tion 507(b)(2) transfer of all or part of its net assets to another private foundation, the appli­cable time period described in excess business holdings will include the respective holding periods of both the transferor and the transferee.  Except as oth­erwise provided in transfer to an effectively con­trolled foundation, the provisions relating to taxable expenditures will not apply to the transferee or to the trans­feror for any expenditure responsibility grants made by the transferor during any period in which the transferor has no assets.  However, the information reporting requirements ­relating to taxable expenditures remain in effect.

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