In PLR 201007064, the IRS ruled that a private organization did not engage in self-dealing upon the transfer of assets to a separate private organization. The transfer of assets was due to a settlement agreement reached between certain members and directors of the transfering organization after a dispute arose over the interpretation of corporate governance provisions. Because the recipient organization did not constitute a disqualified person, the transfer of assets did not constitute self-dealing, even though the transfer of assets did constitute a reorganization between the private foundations.
See also PLR 201007065.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal.
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