C.2. Transfers Made During Section 507(b)(1)(B) Terminations

(1) A transfer from a private foundation to one or more other private foundations,

during a Section 507(b)(1)(B) termination, will constitute a transfer described in Section 507(b)(2) and Treas. Reg. 1.507-3. Even though the transferor satisfies the requirements of Section 507(b)(1)(B) thereafter, thereby successfully terminating its private foundation status, Treas. Reg. 1.507-2(e) will not apply, and such transfer will still be treated as a Section 507(b)(2) and Treas. Reg. 1.507-3 transfer, rather than as a transfer from an organization described in Sections 509(a)(1), (2), or (3).