IRS PLR: Request for Recognition of Unusual Grant Granted (IRC §170)

The IRS has issued a private letter ruling on Section 1.170A-9(f)(6)(ii) of the Treasury Regulations concluding that the transfer of assets from a Type I supporting organization to taxpayer as part of a merger qualifies as an unusual grant for purposes of exclusion from the public support test under IRC Sections 509(a)(1) and 170(b)(1)(A)(vi). The unusual grant determination allows taxpayer to exclude real property from the supporting organization from both the numerator and denominator of the public support test in the tax year in which it is received. [PLR 202539017]

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