To complicate matters further, if this qualifying distribution
was used to pay undergraduate tuition, the taxpayer is entitled to an additional itemized deduction of up to $ 10,000 per qualifying undergraduate student.
These could raise self-dealing, taxable expenditure, qualifying distribution
, and other concerns for the private foundation.
If the distribution from a Roth IRA is not a qualifying distribution
(for whatever reason), the distribution is includible in the taxpayer's income to the extent attributable to earnings.
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
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.
EXHIBIT 2 TAX-FAVORED EDUCATION SAVINGS VEHICLES Qualified Tuition Program Applicable IRC section 529 Tax benefit Account investment earnings not taxed Maximum contribution Determined by QTP plan provisions; generally equal to amount necessary to provide for QEEs Maximum annual Amount of QEEs qualifying distribution
MAGI phaseout No phaseout Whose expenses?
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.
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.