Clarifying examples meant to provide guidance to private foundations with regard to program-related investments have been issued by the IRS in TD 9762, adding the examples at the end of Reg. §53.4933-3(b). The examples generally are the same as those found in the proposed regulations with one example clarified based on comments received.Read More
In response to concerns about potential exposure of a private foundation and its manager to the tax under §4944(a) if it makes an investment this not a program related investment (PRI) but which would still further its charitable purposes the IRS issued Notice 2015-62.
A tax is imposed both on a private foundation and an investment manager if the foundation makes an investment that jeopardizes the carrying out of any of its exempt purposes.Read More