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 private foundation’s set-aside of funds for historic property restoration, treating the set-aside as a qualifying distribution under the minimum distribution requirements where the foundation demonstrated the project is better accomplished through a set-aside than immediate payment and the amount will be paid within the required 60-month period. [PLR 202623019]

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