Although it’s well known that a private foundation (PF) can freely make grants to Internal Revenue Code Section 501(c)(3) public charities, many are surprised to learn that a PF may make a grant to a for-profit organization (FPO)1 by satisfying certain requirements.2 Due to the potential for the enrichment of private interests, however, a PF must contend with an added layer of complexity when granting to an FPO. The PF needs to conduct a private benefit analysis, as the
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