Private Foundation Taxable Expenditures: Limitation on initial tax on foundation managers
The initial tax on the foundation managers is imposed only in cases when the following circumstances are present:
-
The initial tax on taxable expenditures is imposed on the private foundation making the expenditure,
-
The foundation manager agrees to the making of the expenditure knowing that it is a taxable expenditure, and
-
The foundation manager's agreement is willful, and
-
The foundation manager's agreement is not due to reasonable cause.
The tax on any particular expenditure applies only to agreements of:
-
Foundation managers with authority to approve, or to exercise discretion in recommending approval of, the expenditure, and
-
Foundation managers who are members of a group authorized to approve or recommend the making of the expenditure, such as the foundation's board of directors or trustees.
Return to Life Cycle of a Private Foundation
Page Last Reviewed or Updated: 2012-08-14
