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J. BASIC DETERMINATION RULES FOR PUBLICLY …
J. BASIC DETERMINATION RULESFOR PUBLICLY SUPPORTED ORGANIZATIONS AND SUPPORTING ORGANIZATIONS by John F. Reilly and David W. Jones 1. Introduction To a great extent, the Tax Reform Act of 1969 is based on the distinction between private foundations and public charities. Private foundations are subject to the excise taxes imposed by IRC Chapter 42, while public charities are not. It is, therefore, most advantageous for an IRC 501(c)(3) organization to be classified as a public charity rather than as a private foundation. IRC 509 makes the statutory distinction between private foundations and public charities -- it provides that all organizations, foreign and domestic, described in IRC 501(c)(3) are private foundations except the types of organizations set forth in IRC 509(a)(1), (2), (3), or (4).
Oct 16, 1972 · J. BASIC DETERMINATION RULES FOR PUBLICLY SUPPORTED ORGANIZATIONS AND SUPPORTING ORGANIZATIONS by John F. Reilly and David W. Jones 1. Introduction
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