#private-foundations

Private Foundations

Governance, payout requirements, and tax rules for private charitable foundations, including program-related investments and excise tax compliance

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September 17, 202613 min read

Public Charity or Private Foundation? How the 509(a) Tests Decide Your Nonprofit's Tax Fate

Miss the 509(a) support tests and the IRS reclassifies you as a private foundation: 1.39% investment income tax, 10% self-dealing tax, Form 990-PF yearly.

Mike Thrift

nonprofitprivate-foundationstax-compliance

July 12, 20269 min read

Program-Related Investments: How Private Foundations Recycle Charitable Capital

Program-related investments let a private foundation count loans, equity stakes, or guarantees toward its mandatory 5% annual payout, then reclaim the capital as it's repaid, but PRIs to non-charitable recipients trigger IRS expenditure-responsibility rules with a 20% excise tax and personal manager penalties for noncompliance.

Mike Thrift

charitable-givingtax-compliancecompliance

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