IRS updates private foundation rules on MRIs and equivalency determinations
The Internal Revenue Service has given new approval to mission related investments by private foundations and spelled out specific requirements for making “good faith determinations” that grants to foreign organizations are qualifying distributions that don’t require expenditure responsibility. The Tax Code, in Section 4944, imposes an excise tax on private foundation investments that “jeopardize the carrying out of any of its exempt purposes,” but specifically excepts from the limitation “program related investments” where the primary purpose is to accomplish its charitable purpose and “no significant purpose” is the production of income or the appreciation of property. ( See Ready...
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