Private Foundation Rules: A Compliance Guide for Founders

Every U.S. private foundation must file Form 990-PF annually with the IRS, distribute at least 5% of net investment assets each year under IRC §4942, avoid all prohibited self-dealing transactions under IRC §4941, and pay an excise tax on net investment income under IRC §4940. These obligations flow directly from IRC §§4940–4945, the statutory backbone of private foundation rules. If you run a family or single-donor foundation, treat this as a compliance-first entity: calendarize your filings, document every governance decision, and get counsel before correcting any violation rather than after.

Pro Tip: Set a recurring calendar reminder for the 15th day of the 5th month after your fiscal year ends — that is your Form 990-PF due date, and missing it triggers automatic penalties.

Key Takeaways

Table of Contents

• What makes a private foundation different from a public charity?
• The core private foundation rules every foundation must follow
• What happens when rules are broken: penalties and correction steps
• How the 5% minimum distribution rule actually works
• Practical governance: preventing self-dealing before it happens
• State registrations and other non-IRS obligations to track
• How to form a private foundation and how to end its status
• Your annual compliance calendar
• What foundations must disclose publicly beyond Form 990-PF
• Limits on political activities and lobbying
• Grants to donor-advised funds and supporting organizations: the rules and restrictions
• Self-correction procedures for inadvertent violations
• What advisors repeatedly see go wrong — and what good management looks like
• Chisholmfirm supports private foundations through every compliance stage
• Sources

What makes a private foundation different from a public charity?

Under IRC §509, every organization that qualifies for exemption under §501©(3) is a private foundation unless it meets one of the statutory exclusions. Those exclusions cover churches, schools, hospitals, and organizations that receive broad public support — what the IRS calls public charities. If your organization does not satisfy one of those tests, it is a private foundation by default.

The practical difference is funding structure. Public charities draw support from many donors, government grants, and program revenue. Private foundations typically receive funding from a single family, individual, or corporation. That narrow donor base is precisely why the IRS applies stricter rules: without broad public accountability, the law substitutes a detailed regulatory framework to protect the public interest.

Two main types of private foundations:

• Private non-operating (grant-making) foundation. This is the most common structure for family foundations. It pools assets, invests them, and distributes grants to public charities and other qualifying recipients. The full Chapter 42 excise-tax framework applies, including the minimum distribution requirement.
• Private operating foundation. This type directly conducts charitable programs rather than primarily making grants. To qualify, it must pass an income test (spending at least 85% of adjusted net income or minimum investment return on active programs) plus one of three supplemental tests. Operating foundations face a reduced excise tax rate and are exempt from the minimum distribution requirement as applied to non-operating foundations.

Most family foundations end up as non-operating foundations because they are not set up to run programs directly. Founders who want operating-foundation status need to plan for it from the start, because reclassification after the fact requires meeting the statutory tests and notifying the IRS.

The 27-month rule is a critical trap for new organizations. If a newly formed §501©(3) organization that would otherwise qualify as a public charity fails to file Form 1023 within 27 months of formation, it may be treated as a private foundation retroactively — subjecting it to years of more onerous regulation and potential excise taxes. Filing promptly protects classification.

The core private foundation rules every foundation must follow

Think of this as your operational checklist. Each item below corresponds to a statutory requirement with real financial consequences for non-compliance.

1. Annual filing: Form 990-PF

Every private foundation must file Form 990-PF annually, regardless of asset size or income. The return covers revenue, expenses, assets, officer compensation, grant activity, and excise-tax computation. It is a public document — anyone can request a copy, and the IRS posts many returns on its website. That transparency is intentional: Form 990-PF is the primary public accountability tool for foundations.

The due date is the 15th day of the 5th month after the close of the fiscal year (typically in mid-May for calendar-year foundations). A six-month extension is available by filing Form 8868 before the original due date. Late filing penalties start at $20 per day (up to $10,000 for smaller foundations) and can reach $100 per day for larger foundations.

2. Excise tax on net investment income (IRC §4940)

Private foundations pay an excise tax on net investment income — interest, dividends, rents, royalties, and capital gains, net of allowable deductions. The tax rate is fixed under current law without multiple tiers.

If the expected excise tax minus credits will be $500 or more, the foundation must make estimated tax payments using Form 990-W to calculate installment amounts. Deposits are due quarterly. Underpayment of estimated tax carries its own penalty, so foundations with meaningful investment portfolios need to track this throughout the year.

3. Minimum distribution requirement (IRC §4942)

Qualifying distributions include grants to public charities, reasonable and necessary administrative expenses, and program-related investments (PRIs). A detailed worked example appears in the next section.

4. Self-dealing prohibition (IRC §4941)

No financial transaction between the foundation and a disqualified person is permitted, with very limited exceptions. Disqualified persons include substantial contributors, foundation managers, certain government officials, and family members and entities controlled by any of the above. The prohibition covers sales, loans, compensation arrangements, and use of foundation assets — even transactions that appear fair or beneficial to the foundation.

5. Excess business holdings (IRC §4943)

Holdings above that threshold must be divested within prescribed periods.

6. Jeopardizing investments (IRC §4944)

Foundation managers may not make investments that jeopardize the foundation’s ability to carry out its exempt purposes. The IRS looks at whether the investment shows a lack of reasonable business care and prudence. Speculative investments, margin trading, and commodity futures contracts are examples the IRS has flagged.

7. Taxable expenditures (IRC §4945)

Certain categories of spending are “taxable expenditures” that trigger excise taxes unless specific safeguards are in place:

• Grants to individuals (scholarships, travel grants, etc.) require IRS-approved procedures under Revenue Procedure 76-47.
• Grants to organizations that are not public charities (including foreign organizations and certain supporting organizations) require expenditure responsibility — a written grant agreement, monitoring, and reporting back to the IRS on Form 990-PF.
• Lobbying expenditures and grants earmarked for lobbying are prohibited.
• Grants to donor-advised funds (DAFs) are generally treated as taxable expenditures unless specific conditions are met (discussed in detail in the DAF grants section below).
• Any expenditure for political campaign activity is a taxable expenditure.

8. Recordkeeping and public disclosure

Foundations must retain grant files, board minutes, financial records, and correspondence with grantees for a minimum of three years after the return due date, though many practitioners recommend seven years to align with general tax record-retention standards. Keeping records that meet IRS standards is not optional — the IRS Audit Technique Guide specifically examines grant documentation and board minutes during examinations.

Form 990-PF, Form 1023, and any letter of determination must be made available for public inspection upon request. Foundations that post these documents on their own website satisfy the public inspection requirement without having to respond to individual requests.

Pro Tip: Re-run your minimum distribution calculation in October or November each year — before the fiscal year closes — so you have time to make additional qualifying distributions if you are running short. Waiting until after year-end leaves no room to correct a shortfall.

What happens when rules are broken: penalties and correction steps

The IRS does not treat private foundation violations as technical errors. The Chapter 42 excise-tax structure imposes real financial costs on both the foundation and the individuals involved. The IRS Audit Technique Guide describes the enforcement focus and correction procedures in detail.

Common violations and their tax consequences:

Correction procedure, step by step:

1. Identify the violation. Determine which IRC section applies, the amount involved, and who is liable. This step often requires legal counsel because the classification affects which forms to file and what correction looks like.
2. Unwind or reverse the transaction. For self-dealing, the disqualified person must undo the transaction and restore the foundation to its pre-transaction position, including any lost income or appreciation. For distribution shortfalls, make the required distributions as soon as possible.
3. Restore losses. If the foundation suffered a financial loss from the violation (e.g., a below-market loan to a disqualified person), the disqualified person must make the foundation whole.
4. File Form 4720. This is the return for reporting and paying Chapter 42 excise taxes. Both the foundation and any liable managers file separately. An amended Form 990-PF may also be required.
5. Document the correction. Board minutes should reflect the discovery, the correction steps taken, and any policy changes adopted to prevent recurrence.
6. Cooperate with the IRS. Timely correction and cooperation can prevent second-tier taxes from being assessed. The IRS has discretion to abate first-tier taxes in limited circumstances when correction is prompt and the violation was not willful.

Pro Tip: Manager liability is personal — it does not disappear when the foundation pays its tax. A board member who knowingly approves a self-dealing transaction can face personal excise taxes even if they receive no personal benefit. Document your dissent in the minutes if you vote against a questionable transaction.

How the 5% minimum distribution rule actually works

The “roughly” matters: the calculation involves specific adjustments that can move the number up or down.

Step-by-step worked example:

Assume a calendar-year foundation with the following simplified balance sheet at year-end:

1. Determine the fair market value of investment assets. The foundation holds $2,000,000 in a diversified investment portfolio. Cash held for investment purposes is included; assets used directly in charitable programs (program-related assets) are excluded.
2. Subtract acquisition indebtedness. If the foundation borrowed $200,000 to acquire part of the portfolio, net investment assets are $1,800,000.
3. Apply the 5% rate. $1,800,000 × 5% = $90,000. This is the minimum investment return.
4. Subtract the excise tax paid on net investment income. If the foundation paid $5,000 in IRC §4940 excise tax, the distributable amount is $90,000 minus $5,000 = $85,000.
5. That $85,000 is the minimum distribution requirement for the year. The foundation must make qualifying distributions of at least $85,000 by the end of the following tax year (with a one-year carryforward available in limited circumstances).

What counts as a qualifying distribution:

• Grants to public charities and operating foundations
• Reasonable and necessary administrative expenses directly for charitable purposes (salaries, legal fees, accounting)
• Program-related investments (PRIs) — below-market loans or equity investments made primarily for charitable purposes
• Amounts paid to acquire assets used directly in charitable activities

What does not count:

• Grants to private non-operating foundations (unless expenditure responsibility is exercised and the grantee distributes within one year)
• Grants to donor-advised funds (subject to the restrictions discussed below)
• Investment management fees (these reduce net investment income but are not qualifying distributions)
• Capital expenditures for non-program assets

Timing matters. A grant check written on December 31 counts for that tax year only if it is actually paid — a pledge or commitment does not satisfy the requirement until cash or property is transferred. Foundation Source’s practitioner guidance provides useful worksheets for tracking these adjustments throughout the year.

Pro Tip: If your foundation has a distribution shortfall at year-end, a program-related investment can count as a qualifying distribution even though it is technically a loan. PRIs are an underused tool for foundations that want to deploy capital charitably while retaining the asset on the balance sheet.

Practical governance: preventing self-dealing before it happens

Self-dealing violations are the most common finding in IRS private foundation audits, and most of them are preventable with basic governance controls. The problem is rarely bad intent — it is usually a founder who pays a family member for services without documenting the process, or a board that approves a lease with a related party without getting an independent appraisal.

Who counts as a disqualified person:

• Substantial contributors (anyone who has given more than $5,000 and more than 2% of total contributions)
• Foundation managers (officers, directors, trustees, and employees with decision-making authority)
• Owners of more than 20% of a business entity that is a substantial contributor
• Family members of any of the above (spouse, ancestors, descendants, and their spouses)
• Corporations, partnerships, trusts, or estates in which disqualified persons hold more than 35% of the beneficial interest

Board-level controls that reduce self-dealing risk:

1. Adopt a written conflict-of-interest policy that requires annual disclosure from all board members and officers.
2. Require any transaction with a related party to be approved by disinterested board members only — the interested party must recuse from discussion and vote.
3. Obtain an independent third-party appraisal or competitive bids for any compensation arrangement, lease, or purchase involving a disqualified person.
4. Document the approval process in board minutes, including the basis for concluding the transaction is at arm’s length.
5. Review the disqualified-person list annually as the foundation’s donor base and governance structure evolve.

Common self-dealing mistakes and simple guardrails:

• Paying a family member a salary without a documented compensation study: get a comparability analysis from an independent source before setting compensation.
• Renting foundation office space from a board member: even a below-market rent is self-dealing. The foundation must use space it owns or rents from an unrelated party.
• Lending foundation funds to a disqualified person, even interest-free: all loans to disqualified persons are prohibited, regardless of terms.

Pro Tip: For family foundations with multiple generations involved, create a standing governance committee that includes at least one independent member — someone with no family or financial relationship to the founding family. That single structural change dramatically reduces the risk of self-dealing findings and gives the IRS confidence in your process.

State registrations and other non-IRS obligations to track

Federal compliance is necessary but not sufficient. Most states impose their own registration and reporting requirements on charitable organizations, and private foundations are not exempt from them.

State charitable solicitation registration:

If your foundation solicits contributions from the public — including online fundraising campaigns visible to residents of other states — you may need to register in every state where solicitation occurs. The threshold varies by state: some require registration before any solicitation, others set dollar thresholds. Foundations that only make grants and do not solicit the public generally have fewer registration obligations, but the line between “soliciting” and “accepting unsolicited gifts” is not always clear.

Practical steps to check your registration obligations:

1. Identify every state where the foundation solicits, has offices, or makes significant grants.
2. Review each state’s charitable solicitation registration requirements through the state Attorney General’s office or the National Association of State Charity Officials (NASCO) database.
3. Register before soliciting in any new state, not after.
4. File annual renewal reports on each state’s schedule — these are separate from Form 990-PF and have their own deadlines.

Other ancillary obligations:

• State tax filings. Many states require a separate state income or franchise tax return for nonprofits, even if the organization owes no tax. Some states conform to the federal exemption; others require a separate state exemption application.
• State business registration. If the foundation operates or has employees in a state other than its state of formation, it may need to register as a foreign nonprofit corporation in that state.
• IRC §508(e) governing instrument requirements. State corporate statutes do not automatically supply the special provisions that IRC §508(e) requires in a private foundation’s governing instrument. Practitioners recommend drafting those clauses explicitly into the articles of incorporation or trust agreement rather than relying on state law to fill the gap.

Pro Tip: Run a state compliance audit once per year, ideally in the first quarter. Pull a list of every state where the foundation received contributions, made grants, or had staff activity in the prior year — then check registration status for each. This annual sweep catches gaps before they become enforcement issues.

How to form a private foundation and how to end its status

Formation checklist

Getting the formation right protects the foundation from classification surprises and costly amendments later. Here is the sequence that matters:

1. Choose the entity type. Most foundations organize as nonprofit corporations (governed by state nonprofit corporation law) or as charitable trusts. Corporations offer more governance flexibility; trusts may be simpler for single-family situations. Each has different amendment procedures and fiduciary standards.
2. Draft the governing instrument. The articles of incorporation or trust agreement must include the special private-foundation provisions required by IRC §508(e): prohibitions on self-dealing, mandatory distribution language, excess business holdings limits, and restrictions on taxable expenditures. Do not rely on state statute to supply these — draft them explicitly.
3. Obtain an Employer Identification Number (EIN). Apply through IRS.gov before filing any other documents.
4. File Form 1023 for recognition of exemption. Most private foundations file the full Form 1023 (not Form 1023-EZ, which is not available for private foundations). The application asks for the governing instrument, financial projections, and a description of planned activities. Understanding the 501©(3) application process is worth reviewing before you begin.
5. File within 27 months of formation. If the organization files Form 1023 within 27 months of the end of the month of formation, its exempt status is recognized retroactively to the date of formation. Missing that window can result in private foundation status being imposed retroactively.
6. Register with the state. File any required state charitable registration and obtain state tax exemption where applicable.

Essential governing instrument clauses the IRS expects:

• Prohibition on self-dealing with disqualified persons
• Mandatory distribution of income for charitable purposes
• Prohibition on retaining excess business holdings
• Prohibition on jeopardizing investments
• Prohibition on taxable expenditures
• A dissolution clause directing assets to another public charity or government entity upon termination

Termination under IRC §507

A private foundation can end its private foundation status in three ways: voluntary termination by notifying the IRS and paying a termination tax, converting to a public charity by meeting the public support tests for a continuous 60-month period, or transferring all assets to one or more public charities. The termination tax under IRC §507 is designed to recapture the tax benefits the foundation received — it can be substantial, so termination planning requires careful modeling before any action is taken. Nonprofit dissolution involves both federal and state steps that must be coordinated.

Your annual compliance calendar

The table below covers the key annual deadlines for a calendar-year private foundation. Fiscal-year foundations shift each date by the number of months their year is offset from December 31.

Quarter-by-quarter checklist:

• Q1 (January–March): Make Q4 estimated deposit, review prior-year distribution compliance, confirm state registration renewals, hold annual board meeting.
• Q2 (April–June): Make Q1 estimated deposit, file Form 990-PF or extension, review investment portfolio for jeopardizing-investment concerns.
• Q3 (July–September): Make Q2 and Q3 estimated deposits, conduct mid-year grant review, update disqualified-person list.
• Q4 (October–December): Re-run minimum distribution calculation, make year-end grants, prepare for Form 990-PF preparation, review board minutes for completeness.

What foundations must disclose publicly beyond Form 990-PF

Form 990-PF is the most visible public document a foundation produces, but it is not the only one subject to mandatory disclosure. The IRS requires private foundations to make three categories of documents available for public inspection upon request:

• Form 990-PF for the three most recent tax years
• Form 1023 (or Form 1024, if applicable) — the original application for recognition of exemption
• The IRS determination letter granting tax-exempt status

Any person can request these documents in person at the foundation’s principal office during regular business hours, or by written request. The foundation must provide copies within 30 days of a written request (or immediately for in-person requests). Foundations that post all three documents on a publicly accessible website satisfy the inspection requirement without having to respond to individual requests — a practical step that reduces administrative burden.

Foundations may charge a reasonable copying fee but may not charge for inspection. Willful failure to comply with public inspection requirements carries a penalty of $20 per day, up to $10,000 per return.

One point founders often miss: the Form 1023 application is public. That means the foundation’s initial program descriptions, financial projections, and governance structure are visible to anyone who asks. Draft the application carefully — it becomes part of the permanent public record.

Limits on political activities and lobbying

Private foundations face stricter limits on political and lobbying activities than public charities do. The rules are categorical, not a matter of degree.

Political campaign activity: Private foundations are absolutely prohibited from participating or intervening in any political campaign on behalf of or in opposition to any candidate for public office. This prohibition applies to direct contributions, in-kind support, voter guides that favor a candidate, and any expenditure that could influence an election. A single political expenditure is a taxable expenditure under IRC §4945 and triggers excise taxes on both the foundation and the managers who approved it.

Lobbying: Private foundations may not make expenditures to influence legislation, including grants earmarked for lobbying by the recipient. This is broader than the public charity lobbying rules under IRC §501(h): private foundations have no “lobbying expenditure” safe harbor. Even nonpartisan voter registration drives are taxable expenditures unless they meet specific geographic and nonpartisan requirements under IRC §4945(f).

What is permitted: Foundations may conduct nonpartisan research and analysis, publish educational materials on policy issues, and provide technical assistance to government bodies when requested. The key distinction is between education (presenting facts and analysis) and advocacy (urging a specific legislative outcome). That line requires careful judgment, and foundations that want to engage in policy work should get legal review before publishing or funding any policy-related content.

Grants to donor-advised funds and supporting organizations: the rules and restrictions

The rules governing grants from private foundations to donor-advised funds (DAFs) and supporting organizations are among the most frequently misunderstood in the field. Getting them wrong triggers taxable expenditure penalties.

Grants to donor-advised funds: A private foundation grant to a DAF is generally a taxable expenditure under IRC §4945 unless the foundation exercises expenditure responsibility. In practice, most DAF sponsors (community foundations and commercial gift funds) do not accept grants subject to expenditure responsibility because it imposes ongoing monitoring and reporting obligations on the foundation. The result: most private foundation grants to DAFs are not qualifying distributions and carry excise-tax risk. Foundations that want to support a donor’s DAF giving should consult counsel before making the grant.

Grants to supporting organizations: The rules differ depending on the type of supporting organization (Type I, II, or III). Grants to Type III non-functionally integrated supporting organizations are taxable expenditures unless the foundation exercises expenditure responsibility. Grants to Type I and Type II supporting organizations are generally not taxable expenditures, but the foundation must verify the recipient’s classification before making the grant. The IRS’s EO operational requirements guidance addresses these distinctions.

Expenditure responsibility in practice: When a foundation makes a grant subject to expenditure responsibility, it must:

• Execute a written grant agreement specifying the charitable purpose and prohibiting use of funds for lobbying, political activity, or non-charitable purposes
• Require the grantee to maintain the funds in a separate account
• Obtain annual reports from the grantee on how funds were used
• Report the grant on Form 990-PF, Part VII-B

Expenditure responsibility is manageable for grants to foreign organizations or to fiscally sponsored projects, but it adds administrative burden. Many foundations find it simpler to direct grants to public charities that do not require it.

DAF vs. private foundation: Founders sometimes ask whether a donor-advised fund is a simpler alternative. A DAF offers lower administrative costs and no minimum distribution requirement, but the donor gives up legal control over grant decisions once funds are contributed. Private foundations retain full control, offer more grant-making flexibility, and can pay reasonable compensation to family members for legitimate services — advantages that often outweigh the compliance costs for families with significant philanthropic goals. The structural differences between a foundation and a public charity are worth reviewing when making that decision.

Self-correction procedures for inadvertent violations

The IRS recognizes that some violations occur without willful intent, and the correction framework under Chapter 42 is designed to encourage prompt remediation rather than punish honest mistakes.

What “correction” means under IRC §4941 (self-dealing): The disqualified person must undo the transaction to the extent possible and restore the foundation to the financial position it would have been in had the transaction never occurred. If the foundation received less than fair market value in a transaction, the disqualified person must pay the difference. If the foundation paid more than fair market value, the excess must be returned.

Filing requirements for corrections:

• File Form 4720 to report and pay any first-tier excise taxes owed by the foundation and by liable managers. The foundation and each manager file separately.
• File an amended Form 990-PF if the original return did not accurately reflect the transaction or the correction.
• Attach a written explanation of the violation, the correction steps taken, and the date of correction to both filings.

Avoiding second-tier taxes: Second-tier taxes are assessed when a violation is not corrected within the taxable period (generally the period ending 90 days after the IRS mails a notice of deficiency). Prompt correction — before that notice issues — is the most reliable way to avoid second-tier liability. The IRS also has discretion to abate first-tier taxes when the violation was due to reasonable cause and not willful neglect, and when the foundation promptly corrects the error.

When to seek legal counsel: Any time a potential violation is identified, get counsel involved before filing anything. The sequence of correction steps, the characterization of the transaction, and the language used in the written explanation all affect whether the IRS treats the matter as a corrected inadvertent error or an ongoing compliance problem. Early legal involvement consistently reduces both the financial exposure and the audit risk.

What advisors repeatedly see go wrong — and what good management looks like

The compliance failures that cost foundations the most are rarely dramatic. They are quiet, gradual, and almost always preventable.

The most consistent pattern: founders underestimate how public their foundation is. Form 990-PF is not a private document. Every compensation payment, every grant, every investment holding, and every officer’s name is visible to the public, the IRS, and state regulators. Founders who treat the foundation like a private family account — paying relatives without documentation, approving grants informally, skipping board meetings — are building a record that will be difficult to defend in an audit.

The second pattern is distribution drift. Foundations that do not track the minimum distribution calculation quarterly often discover in January that they fell short the prior year. A mid-year distribution review in October or November costs almost nothing and eliminates that risk entirely.

Good management looks like this: a written conflict-of-interest policy that is actually signed annually, board minutes that reflect real deliberation (not just approvals), a distribution tracking spreadsheet updated quarterly, and an annual call with legal counsel and a CPA before the Form 990-PF is filed. That combination catches most problems before they become violations. Foundations that treat governance as a periodic formality are the ones that end up in correction procedures — and correction is always more expensive than prevention.

Chisholmfirm supports private foundations through every compliance stage

Private foundation compliance is not a one-time project. It is an ongoing management responsibility that touches filings, grant-making, governance, and state registrations every year. Chisholmfirm provides legal services specifically designed for foundations at every stage: drafting governing instruments with the IRC §508(e) provisions the IRS requires, preparing and reviewing Form 1023 applications, reviewing Form 990-PF before filing, and handling correction work including Form 4720 preparation when a violation has occurred.

For foundations that want ongoing support, Chisholmfirm offers annual compliance retainer options that cover a pre-filing Form 990-PF review, a distribution calculation check, and a governance audit. Engagements typically begin with an initial compliance review that produces a priority checklist — so you know exactly what needs attention before the next filing deadline. Whether you are forming a new foundation, correcting a past violation, or simply want a second set of eyes on your annual return, a 501©(3) attorney can reduce your exposure and give you confidence that your foundation is operating exactly as the IRS requires. Schedule a consultation with Chisholmfirm to get a clear picture of where your foundation stands.

Sources

The following primary sources are the legal backbone of every private foundation compliance obligation described in this article:

• 2025 Instructions for Form 990-PF
• §509. Private foundation defined

IRC §§4940–4945 are the statutory core of private foundation excise-tax law. Every compliance decision your foundation makes should be traceable back to one of those sections or to the IRS guidance that interprets them.

This article provides general legal information, not legal advice. Private foundation rules are complex and fact-specific. Consult a qualified attorney and CPA before making compliance decisions for your foundation.

This article is general information, not a substitute for advice from a qualified lawyer. Consult a qualified legal professional about your own circumstances before acting on anything here.

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