Special rules for certain foundations and trusts

Special rules apply to certain foundations and trusts, which may also be subject to some or all of the general private foundation excise taxes :

• Private nonoperating foundation distributing all contributions received (sometimes referred to as a private pass-through foundation)
• Private foundation maintaining a common fund
• Nonexempt charitable trusts
• Estates in administration with charitable bequests pending
• Split-interest trusts
• Certain split interest trusts that become charitable trusts
• Foreign foundations
• Certain split-interest trusts that wind up
• Revocable trusts that become charitable trusts
• Trusts devoted to qualified conservation purposes
• Charitable trusts that support public charities (section 509(a)(3) supporting organizations)

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