If an organization is an exempt private foundation on or after October 9, 1969, but it is later determined that it is no longer exempt as a section 501(c)(3) organization as of any date after October 9, 1969, the organization will continue to be treated as a taxable private foundation unless its status as such is terminated under section 507, even though it may operate thereafter as a taxable entity.

Note. If an organization was not exempt on October 9, 1969, it will not be treated as a private foundation, unless it becomes a private foundation on a later date.

  Return to Life Cycle of a Private Foundation