IRS PLR: Private Foundation Not Terminated by Asset Transfers to New Foundations (IRC §507)

The IRS has published a private letter ruling on I.R.C. §§507, 4940, 4941, 4944, and 4945 determining that an I.R.C. §501(c)(3) Foundation, classified as a private foundation, proposing to transfer more than 25 percent of the fair-market-value of its assets to two new foundations: 1) qualifies as the transfer of assets described in I.R.C. §507(b)(2) and will not be described in I.R.C. §507(a); 2) the new foundations will not be treated as newly created organizations as a result of the proposed transfers; 3) the proposed transfers will not give rise to net investment income and will not result in the ...