Private foundation’s receipt of note from founder’s corporation won’t be self-dealing

In PLR 201129049, IRS has privately ruled that a private foundation’s holding of a promissory note and its receipt of promissory note payments from its founder’s corporation after the period of estate administration terminations won’t be treated as acts of self-dealing subject to the Code Sec. 4941(a) excise tax. IRS concluded that the transactions will meet all of the requirements of the “estate administration exception” in Reg. § 53.4941(d)-1(b)(3).

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The attorneys at the Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.

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