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
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