IRS PLR: Foundation’s Status Modified from Public to Private, Exempt Status Unchanged (IRC §509)

The status and classification of a foundation with the purpose of disseminating materials and information on stress-free living modified from public to private, the IRS ruled. The foundation’s failure of the public support and gross income test, because not more than one-third of its support comes from exempt function income, gifts, grants, or membership fees and more than one-third comes from gross investment income and the excess of the amount of unrelated business taxable income under tax code Section 511, means it fails to qualify as a publicly supported organization under Section 509(a)(2) and should reclassified as ...