These could raise self-dealing, taxable expenditure, qualifying distribution
, and other concerns for the private foundation.
4942, grants made for charitable purposes to a foreign organization that does not have a determination letter from the IRS may be treated as a qualifying distribution
if the grantor private foundation makes a "good faith determination" that the foreign organization is a private operating foundation or a public charity (other than a disqualified supporting organization).
A controversial provision of the Act prohibits non-operating private foundations from counting payments to a Type III SO as a qualifying distribution
11, 1992, and a prospectus qualifying distribution
of the common shares upon exercise of the warrants will be filed as soon as possible after closing.
If on November 1, 2008, U obtains a family HDHP, he is eligible to take another qualifying distribution
of up to $2,900--for a total of $6,700 for the year.
Each Special Warrant is exercisable on or before the earlier of October 10, 1997 or five business days after the date on which the last of the receipts for the Company's final prospectus qualifying distribution
of the Units (as defined below) is issued by the appropriate securities regulatory authorities.
Distributions made by one nonoperating foundation or trust to another were subject to a number of conditions and restrictions requiring a "pass-through" of the distribution, whereby the donor organization received credit for a qualifying distribution
but the donee organization did not.
A shareholder who sells his shares to the Company through Cazenove in its capacity as the Company's agent will be treated as receiving a qualifying distribution
for the purposes of UK taxation.
In our example, the participant could separate from service in 2010, make a direct rollover of his account balance to his new employer's plan, and receive a qualifying distribution
from the new plan in 2013 or later.
A qualifying distribution
is one in which the proceeds are used by the individual within 120 days of the distribution date for the acquisition of a principal residence; and the principal residence is acquired by the taxpayer, his or her spouse, or the taxpayer's or taxpayer's spouse's child, grandchild or ancestor.
The foundation's determination of whether a grant is a qualifying distribution
Payments to private nonoperating foundations are not qualifying distributions
, unless the recipient organization makes an equivalent qualifying distribution
by the end of the following year that is treated as a corpus distribution.