Life Cycle of a Private Foundation - Private Letter Rulings


Associate Chief Counsel (Tax Exempt and Government Entities) will generally rule on whether a proposed change to an organization's purpose or activities would further an exempt purpose. Thus, if you are unsure about whether proposed changes would further an exempt purpose, you may want to request a private letter ruling. See Revenue Procedure 2018-1

In some areas, the law requires that an organization notify the Internal Revenue Service or receive an advance determination before undertaking a transaction resulting in certain tax consequences. Thus, a foundation must request a private letter ruling or determination with respect to the following issues:

A foundation must also notify the IRS when it intends to terminate its private foundation status voluntarily under Code section 507(a)(1).

Additional information


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