A private foundation may voluntarily terminate its status under section 507(b)(1) by either (1) transferring all its net assets to one or more public charities each of which has been in existence and so described for a continuous period of at least 60 months immediately preceding the distribution, or (2) operating as a public charity under sections 509(a)(1), (2), or (3) continuously for 60 months beginning with the first day of any tax year.  Private foundation status may not be ter­minated under either of these methods if there have been either willful repeated acts (or failures to act) or a willful and flagrant act (or failure to act) that gives rise to liability for private foundation excise taxes.

Additional considerations:


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