Treatment of substantial contributors of transferor foundation after Section 507(b)(2) transfer

A substantial contributor of the transferor foundation will be considered a substantial con­tributor of the transferee organization even if the individual does not meet the definition of a sub­stantial contributor with respect to the transferee organization.  With respect to the transferor foun­dation, a person is a substantial contributor if the person contributed or bequeathed an aggregate amount of more than $5,000 to the foundation, provided that the amount contributed is more than 2 percent of the total contributions received by the foundation before the close of the taxable year in which the contribution or bequest is received by the foundation.

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