Preface ix Book Citations xi Chapter 1: Introduction to Private Foundations 1 1.6 Foundations in Overall Exempt Organizations Context 1 1.10 Private Foundations Sanctions 1 Chapter 2: Starting and Funding a Private Foundation 3 2.5 Acquiring Recognition of Tax-Exempt Status 3 2.7 When to Report Back to the IRS 18 Chapter 3: Types of Private Foundations 19 3.1 Private Operating Foundations 19 3.1A Exempt Operating Foundations 19 Chapter 4: Disqualified Persons 21 4.4 Family Members 21 Chapter 5: Self-Dealing 23 5.1 Private Inurement Doctrine 23 5.3 Definition of Self-Dealing 24 5.4 Sale, Exchange, Lease, or Furnishing of Property 24 5.6 Payment of Compensation 26 5.8 Uses of Income or Assets by Disqualified Persons 26 5.10 Payments to Government Officials 27 5.11 Indirect Self-Dealing 28 5.12 Property Held by Fiduciary 29 5.15 Issues Once Self-Dealing Occurs 29 Chapter 6: Mandatory Distributions 31 6.2 Assets Used to Calculate Minimum Investment Return 31 6.5 Qualifying Distributions 31 6.7 Satisfying the Distribution Test 33 Chapter 7: Excess Business Holdings 35 7.1 General Rules 35 7.2 Permitted and Excess Holdings 36 7.3 Functionally Related Businesses 36 7.4 Rules Applicable to Certain Supporting Organizations 37 7.6 Excise Taxes on Excess Holdings 37 Chapter 8: Jeopardizing Investments 39 8.1 General Rules 39 8.2 Prudent Investments 39 8.3 Program-Related Investments 40 Chapter 9: Taxable Expenditures 43 9.1 Legislative Activities 43 9.2 Political Campaign Activities 44 9.3 Grants to Individuals 44 9.4 Grants to Public Charities 44 9.4A Grants to Exempt Operating Foundations 45 9.5 Grants to Foreign Organizations 46 9.6 Expenditure Responsibility 47 9.9 Distributions to Certain Supporting Organizations 47 9.10 Excise Tax for Taxable Expenditures 47 Chapter 10: Tax on Investment Income 49 10.3 Formula for Taxable Income 49 Chapter 11: Unrelated Business Income 51 11.1 General Rules 51 11.2 Exceptions 51 11.3 Rules Specifically Applicable to Private Foundations 51 11.5 Calculating and Reporting the Tax 52 Chapter 12: Tax Compliance and Administrative Issues 53 12.1 Successful Preparation of Form 990-PF 53 12.2 Reports Unique to Private Foundations 57 12.3 Compliance Issues 57 Chapter 13: Termination of Foundation Status 63 13.4 Operation as a Public Charity 63 13.5 Mergers, Split-Ups, and Transfers between Foundations 63 Chapter 15: Private Foundations and Public Charities 67 15.4 Publicly Supported Organizations Donative Entities 67 15.5 Service Provider Organizations 67 15.7 Supporting Organizations 68 15.8 Change Of Public Charity Category 79 Chapter 17: Corporate Foundations 81 17.3 Private Inurement Doctrine 81 17.5 Self-Dealing Rules 81 Chapter 18: Nonprofit Governance and Private Foundations (New) 83 18.1 State Law Overview 84 18.2 Board of Directors Basics 88 18.3 Principles of Fiduciary Responsibility 91 18.4 Duties of Directors 92 18.5 Board Composition and Federal Tax Law 93 18.6 Sources of Nonprofit Governance Principles 95 18.7 Relevant Nonprofit Governance Issues 122 18.8 Nonprofit Governance Policies 145 18.9 Role of IRS in Nonprofit Governance 146 18.10 Governance Principles and Private Foundations 156 Cumulative Table of Cases 163 Cumulative Table of IRS Revenue Rulings and Revenue Procedures 167 Cumulative Table of IRS Private Determinations Cited in Text 171 Cumulative Table of IRS Private Determinations Discussed in Bruce R. Hopkins' Nonprofit Counsel 179 Cumulative Table of IRS Private Letter Rulings, Technical Advice Memoranda, and General Counsel Memoranda 183 Table of Private Foundation Law Tax Reform Proposals 201 About the Authors 211 About the Online Resources 213 Cumulative Index 215.

The must-have tax law reference for private foundations, updated for 2017 Private Foundations provides an authoritative reference and extensive analysis of tax law and compliance in the private foundation's arena, with a wealth of practical tools to streamline applications, filing, and reporting.