In PLR 201737003, the Service ruled that a foreign private foundation’s holding of a business investment in a foreign corporation that indirectly holds as much as 100 percent of a foreign business entity’s voting stock does not constitute an excess business holding under Code Section 4943 because the foundation won’t own more than 20 percent of the entity’s voting stock.

See full PLR 201737003 by clicking here.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.