Except as otherwise provided in Transfer to an effectively controlled foundation, a pri­vate foundation must meet the distribution requirements for any year in which it makes a section 507(b)(2) transfer of all or part of its net assets to another private foundation. The transfer itself will be counted as a qualifying distribution if it meets the require­ments to be considered such a distribution.  However, when the transferor has disposed of all its assets, the recordkeeping requirements will not apply to any period in which it has no assets.


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