Discussion:Private Foundation with foreign donee
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Discussion Forum Index --> Advanced Tax Questions --> Private Foundation with foreign donee
Discussion Forum Index --> Tax Questions --> Private Foundation with foreign donee
| 17 May 2008 | |
| My client wants to meet with me regarding setting up a PF that will fund nursing education in the Phillipines. This client is reasonably sophisticated and (happily for me) follows advice extremely well. She is shareholder/member in 8 Corps & LLCs, has family LLCs, irrevocable & revocable trusts. Really an ideal client.
As I mentioned, she wants to fund nursing education in the Phillipines (her home country). I'm way short of being an expert on PFs, but I suggested that in order to make charitable contributions to a foreign country, she either had to make donations to a current 501(c)(3) org, or create one herself. She doesn't have the support for an independent board, so a PF seems to be the way to go. Can anyone point me toward good resources for this situation? I'll be grateful for any advice. | |
| 20 May 2008 | |
| A PF is a 501(c)(3) organization. I see no problem with what you are suggesting.
Donations, made either directly or indirectly to a charitable organization formed under the laws of a foreign country are not deductible. Your client cannot make a deductible gift to a domestic 501(c)(3) organization with an understanding that the 501(c)(3) organization will forward the gift to a foreign charitable organization. See Rev. Rul. 63-252, examples 1,2, and 3. However, I see no problem with setting up a domestic 501(c)(3) organization for the purpose of making grants to student nurses in the Phillipines. See Rev. Rul. 63-252, examples 4 and 5. | |
