CHAPTER ONEIntroduction to Private Foundations

  1. § 1.6 Foundations in Overall Exempt Organizations Context
  2. *§ 1.10 Private Foundations Sanctions

§ 1.6 FOUNDATIONS IN OVERALL EXEMPT ORGANIZATIONS CONTEXT

p. 18, note 82. Insert as second paragraph:

The Tax Exempt and Government Entities Division, on October 1, 2015, issued its work plan for the federal government's fiscal year 2016. This work plan identifies TE/GE's five key areas of focus in the coming months. One of these areas is “knowledge management.” The Division is developing a “knowledge management framework,” which entails gathering information from employees and staffing the “knowledge networks” (what the IRS likes to refer to as “K-Nets”). The IRS has begun building knowledge libraries within each K-Net, containing technical resources searchable by key issue areas and resource type. One K-Net that is currently under way concerns private foundation tax law.

*§ 1.10 PRIVATE FOUNDATIONS SANCTIONS

p. 26, second complete paragraph, last line. Insert footnote at end of line:

*137.1

Even the IRS, from time to time, gets this one wrong. For example, in a private letter ruling, the IRS stated that certain payments to disqualified persons by a private foundation “would be acts of self-dealing that are prohibited by Chapter 42 of the Internal Revenue Code” (Priv. Ltr. Rul. 201703003).

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