In PLR 201005054, the IRS ruled that set-asides for a redeveloptment project made by a private operating foundation exempt from taxation under Internal Revenue Code sections 4942(j)(3) and 4940(d)(1) were qualifying distributions and satisfied the suitability test under Code section 4942(g)(2). The IRS found that the project would accomplish the purpose of relief to orphans and other destitute children, that the amount set aside for the project would be paid out within 60 months as required by the Code, and that the project could be better accomplished with the set-aside rather than through the immediate payment of funds.
See also PLR 201005055.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal.
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