Topic Index: Private Foundations

Rulings Go Beyond ‘Plain Vanilla’ Foundations

By Gerald B. Treacy, Jr.

Originally Published in Taxation of Exempts, September 2007

Thus far, 2007 has generated four private letter rulings of more than casual interest relating to private foundations. Unusually, two of the rulings relate to the generally quiet area of private operating foundations under Section 4942(j)(3). A private operating foundation, or POF, is an “elevated” form of private foundation, which, in contrast to its more […]

A Taxonomy of Tax-Exempt Organizations

By Gerald B. Treacy, Jr.

Originally Published in Planned Giving Today, June 1997

Ask a representative of a charitable organization what type of charity he or she represents, and the correct, if incomplete, answer will often be, “We’re a 501(c)(3) organization.” This basic qualification will likely be only part of the answer sought. Most tax-exempt charitable institutions–private foundations, public charities and the variety of hybrids between–share this basic […]