(1) A company controlled private foundation often provides grants or loans to
employees in "emergency" circumstances. For example, funds are sometimes
provided for employees who:
a. Suddenly incur extraordinary medical expenses on their own behalf or on
behalf of members of their families;
b. Experience emergencies arising from natural disasters such as hurricanes,
tornadoes, fires, floods, or earthquakes not covered by insurance or other
resources. In the past, public notices, such as Notice 92-45, 1992-2 C.B. 375
(Organizations Providing Relief to Victims of Hurricanes Andrew and Iniki)
and Notice 93-41, 1993-2 C.B. 332 (Organizations Providing Relief to Victims
of the Midwest Floods) provided relaxation from strict adherence to the
Chapter 42 requirements imposed on private foundations during national
disaster situations;
c. Suffer physical injuries or financial losses by way of being victims of violent
crimes that are not covered by insurance or other resources; and
d. Need funds for funeral or burial expenses.
(2) In the legislative history of the Victims of Terrorism Tax Relief Act of 2001,
Congress set forth guidelines for company-controlled private foundations in
providing disaster relief to company employees and directed the IRS to issue
prompt guidance, which was provided in Publication (Pub.) 3833, Disaster Relief,
Providing Assistance Through Charitable Organizations.
