Many practitioners and other advisors who have regular dealings with private foundation (PFs) are well aware of the direct self-dealing rules, which severely limit the financial transactions that may occur between a PF and its insiders, technically termed “disqualified persons” (DPs), as defined in Internal Revenue Code Section 4946. Although the direct self-dealing rules are arguably well-defined, the indirect self-dealing rules are fraught with ambiguity. Surprisingly, “indirect self
ARTICLE ACCESS REQUIRED
Please Log in if you are currently a Trust&Estates subscriber, or select DAYPASS for our new 24 hour access (nominal fee required).
If you are interested in unlimited article access for one year, please select Annual Subscription below.