The team at Dodson Parker Behm & Capparella, PC shares updates and thoughts on developments in the law.

Guidance Issued for Private Foundations with Foreign Grantees

November 8, 2017

New guidance for private foundations from the IRS addresses treatment of foreign grantees.  The groups may wish to treat grants to foreign grantees as qualifying distributions that satisfy the minimum distribution requirements rather than as expenditures requiring expenditure responsibility.

If a private foundation makes a “good faith determination” that a foreign grantee qualifies as a qualifying public charity, as defined in Revenue Procedure 2017-53, the grant will generally be a qualifying distribution that does not require expenditure responsibility in order to not be a taxable expenditure.  A major development is that the new procedure supersedes Rev. Proc. 92-94, which allowed a private foundation to avoid expenditure responsibility if it had an equivalency determination, such as a grantee affidavit.

Post by: Jillian Mastroianni

 


▼  More from the Blog  ▼


CONTRIBUTORS



Tweets 

5 days ago
ICYMI:
An excellent read featuring DPBC’s @MargaretLBehm alongside Jeanie Nelson and Juli Mosley, as they seek to honor the fight of our suffragist forbearers.

https://t.co/OQtuhUiidV

Dodson Parker Behm and Capparella PC
1310 Sixth Avenue North
Nashville, TN 37208

Ph. 615-254-2291 | Directions

Terms of Use
Copyright Policy


The information found on this website is not intended as legal advice. You should not act on any information contained within the website without consulting legal counsel regarding your particular situation.

We’re proud to call Nashville’s Historic Germantown Neighborhood our home.
You’ll find us here 7:30am – 5:30 pm weekdays.

Privacy Policy