PLR 201021045: IRS Rules Ownership of Stock Will Not Constitute Excess Business Holdings

In PLR 201021045, the IRS ruled that ownership of voting common stock by an organization described in Section 501(c)(3) and classified as a foundation in Section 509(a) will not constitute excess business holdings under Section 4943 if the organization distributes at least 80 percent of the voting common stock to its supporting organizations within the five-year period from the day the the stock is distributed to the organization.

Posted by Neil I. Rumbak, Associate Editor, Wealth Strategies Journal.