PFS2102. Transactions with disqualified persons in the family office setting

This session will focus on private foundations in the family office environment and how to protect the disqualified persons and managers from incurring excise tax penalties.  We will discuss co-investments, current, and future gifts when debt is associated with the asset transfer, and planning for estate gifts. Current guidance on self-dealing and potential use of the "Newman's Own" exception to excess business holding prohibition.  We will look at planning opportunities, available private letter rulings, the existing law that can be relied upon until the IRS issues further guidance and proposed legislation.

Learning Objectives:

• Explore current guidance and rules for private foundations and transactions with disqualified persons
• Examine potential future legislation and impact on planning for private foundations