When a Small Foundation Becomes a “Private Foundation”

With the increase in wealth in rural areas in recent years has come the growth in non-profit organizations, often organized as family entities to assist in perpetuating some feature of rural life. The focus may be on the local schools; colleges or universities, often in the form of scholarships; the local church; soil conservation; the local community itself or any one of a number of other family concerns. Most are organized as corporations under state law and have sought (and usually obtained) federal status to operate “. . . for religious, charitable, scientific, testing for public safety, literary or educational purposes. . . “ along with some additional charitable functions.1 This is the highest status recognized in the United States for deductibility for federal income, gift and estate tax purposes and is known as “Section 501(c)(3)” status.2