p. 153. First paragraph, last line, insert note at end of line:
1.1.
The facts of an IRS private letter ruling serve as an illustration of the many ways a person can be a disqualified person with respect to a private foundation (Priv. Ltr. Rul. 201433021).
p. 162. First paragraph, insert as last sentences:
Thus, in one instance, the IRS ruled that sale of property to a disqualified person with respect to a private foundation will not result in direct or indirect self-dealing, the latter avoided in part because of the rule that brothers and sisters are not disqualified persons, as a consequence of that relationship, in this context.60.1 In another case, conversion of a trust, treated as a private foundation, from nongrantor to grantor status will not entail self-dealing because the parties involved, being siblings, are not disqualified persons.60.2
p. 162, note 60. Insert following existing text:
In the intermediate sanctions context, however, individuals in these categories are included in the definition of disqualified person (IRC § 4958 (f)(1)(B), (f)(4)).
18.117.73.85