IRS Issues PLR Approving Private Foundation Set-Aside as Qualifying Distribution

The IRS has issued a private letter ruling on I.R.C. §4942 and Treas. Reg. §53.4942 approving a set-aside allowing a private foundation to treat an amount designated for historic property restoration as a qualifying distribution, provided the foundation pays the set-aside amount within 60 months and documents the obligation in its records, with the set-aside amount considered when determining minimum investment return and adjusted net income calculations. [PLR 202622008]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.