If total Tax Year 2009 qualifying distributions
were larger than the total of averaged qualifying distributions
made between 2004 and 2008 plus 1 percent of Tax Year 2009 net investment income, a foundation was eligible for the reduced tax rate for Tax Year 2009.
Private Foundations: Achieving Maximum Use of Excess Qualifying Distributions
," The Tax Adviser, April 02, page 225
The status of the economy and the stock market affect assets and giving levels, which in turn affect the charitable administrative expense portion of qualifying distributions
The House bill also includes a provision that would reduce the excise tax on private foundation investment earnings and eliminate administrative expenses from qualifying distributions
for all private foundations.
from these programs will no longer be subject to tax.
You also can claim a Hope or Lifetime Learning Credit, and exclude qualifying distributions
from an Education IRA in the same year, as long as the distribution isn't used for the same expenses as the credits.
39808 (January 16, 1990), the IRS held that a taxpayer's excess distribution carryover applicable to years not barred by the statute of limitations can be adjusted by recalculating the distributable amount or the amount of qualifying distributions
for years that are closed.
federal corporate income tax on its investment income if the company makes qualifying distributions
of its income to stockholders.
In addition, grants to this type of supporting organization are not included in qualifying distributions
for purposes of meeting the distribution requirements.
They also cannot count payments to other types of SOs which are controlled by disqualified persons of the foundation as qualifying distributions
Although qualifying distributions
generally consist primarily of contributions, gifts, and grants disbursed throughout the year, they may also include operating and administrative expenses related to conducting charitable operations; "set-asides," which are amounts earmarked for future charitable distributions; program-related investments, such as loans to other 501 (c)(3) organizations; and amounts paid to acquire buildings, equipment, supplies, or other assets for charitable-use.
Members of a consolidated group generally elect the 100 percent dividends-received deduction under section 243(a)(3) of the Code for qualifying distributions