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 as precedent by other taxpayers or […]