PLR 202119002: Private Foundation Grants to Intermediary Foreign Organizations

Earlier this year, the IRS released a private letter ruling (PLR 202119002) on a private foundation’s contemplated grants to three foreign organizations that will each regrant the applicable funds to secondary grantees in furtherance of the private foundation’s 501(c)(3) exempt purposes. While a PLR may not be relied on...

2021 Georgetown EO Conference: Legal and Tax Issues for Foreign Offices and Affiliates

Georgetown Law held its 38th Annual Representing and Managing Tax-Exempt Organizations conference (virtual edition) last month. Among the sessions at the conference was Legal and Tax Issues for Foreign Offices and Affiliates presented by Stephanie Biden, Ricardo A. Castro, and Curtis Saueressig. Below are some of the many highlights from their...