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Tag Archives: good faith determination

Proposed Regulations Change Rules Governing Good Faith Determinations of a Foreign Organization’s Equivalence to a Public Charity

Posted in IRS Filings, Private Foundations

The IRS recently issued proposed regulations amending the rules applicable to a private foundation’s good faith determination that that a foreign grantee is the foreign equivalent of a public charity or private operating foundation, grants to which will be “qualifying distributions” and not “taxable expenditures.” Most significantly, the proposed regulations expand the class of practitioners… Continue Reading