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).

Read More