Private Foundation Leasing of Business Assets: Hearing Before the Subcommittee on Taxation and Debt Management Generally of the Committee on Finance, United States Senate, Ninety-fifth Congress, First Session, on S. 1514 ... July 25, 1977

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Page 2 - At the time with respect to which subdivision (i) of this subparagraph is applied, the transaction would not have constituted a prohibited transaction within the meaning of section 503(b) or the corresponding provisions of prior law if such provisions had been applied at such time.
Page 2 - ... (C) the leasing of property or the lending of money or other extension of credit between a disqualified person and a private foundation pursuant to a binding contract In effect on October 9, 1969 (or pursuant to renewals of such a...
Page 2 - January 1, 1977" and inserting in lieu thereof "January 1, 1990". (c) Section 101(1) (2) (C) of the Tax Reform Act of 1969 is amended by striking out "December 31, 1979" and inserting in lieu thereof "December 31, 1989".
Page 1 - ... exempt from federal income tax under section 501 (c) (3) of the Internal Revenue Code...
Page 19 - ... (A), (B), or (C), or members of their families (within the meaning of subsection (d)), who made (directly or indirectly) substantially all of the contributions to the private foundation in question, and "(I) only for purposes of section 4941, a government official (as defined in subsection (c)). "(2) SUBSTANTIAL CONTRIBUTORS. — For purposes of paragraph (1), the term 'substantial contributor' means a person who is described in section 507(d)(2).
Page 19 - For purposes of paragraph (1), the term "substantial contributor" means any person who contributed or bequeathed an aggregate amount of more than $5,000 to the private foundation, if such amount is more than 2 percent of the total contributions and bequests received by the foundation before the close of the taxable year of the foundation in which the contribution or bequest is received by the foundation from such person. In the case of a trust, the term "substantial contributor" also means the creator...
Page 2 - ... (D) the furnishing of goods, services, or facilities by a private foundation to a disqualified person shall not be an act of selfdealing if such furnishing is made on a basis no more favorable than that on which such goods, services, or facilities are made available to the general public...
Page 19 - ... use of goods, services, or facilities which are shared by a private foundation and a disqualified person until taxable years beginning after December 31, 1979, if such use is pursuant to an arrangement in effect before October 9, 1969, and such arrangement was not a prohibited transaction (within the meaning of section 503 (b) or the corresponding provisions of prior law...
Page 18 - Another grandfather clause currently permits property, leased by a private foundation to a disqualified person at the time of passage of the Tax Reform Act of 1969, to be sold for at least fair market value to the disqualified person.
Page 11 - In other words, if the difference between the fair market value and the sale price was $10 million, let us say, then these contributions that they made would not be very large in percentage.

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