The IRS has issued a private letter ruling on I.R.C. §509 and Treas. Regs. §§1.170A and 1.509 determining that a substantial cash grant from Foundation to taxpayer qualifies as an unusual grant exclusion for public support testing purposes, allowing taxpayer to maintain its I.R.C. §509(a)(2) public charity status. [PLR 202623021]
This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.