Summary: | " ... discusses the definition and classification of private foundations and public charities. Under [section] 509, enacted by The Tax Reform Act of 1969, certain [section] 501(c)(3) organizations (charitable, educational, religious organizations) are classified as private foundations. Organizations classified as private foundations are subject to restrictions and requirements in addition to those applicable to exempt charities generally. Under [section] 4942(j)(3), also added by the 1969 Tax Reform Act, certain private foundations, known as private operating foundations, are exempted from some of those burdens placed on private foundations. Those private operating foundations, known as exempt operating foundations, are exempt from the [section] 4940 tax on investment income as well. Certain non-operating private foundations also receive special treatment."
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