Private Foundations Acting in Good Faith May Rely on Written Advice of Circular 230 Practitioners to Determine Foreign Charity Status
The IRS has provided in final regulations (TD 9740) that a private foundation may rely in good faith in making a determination that a foreign organization is a charitable organization that is not itself a private foundation by relying in good faith upon written advice from any of the following tax practitioners:
- Attorney
- Certified Public Accountant
- Enrolled Agent
who are subject to IRS regulation via Circular 230 (traditional Circular 230 practitioners).
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