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Exempt Organizations Technical Guide›TG 3-22: Termination of Private Foundation Status - IRC Section 507›Table of Contents

Tax Liability on Transferred Assets

0324 Publ 5614 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States

(1) In determining Section 507(c) tax liability in the case of assets transferred by a

private foundation, the tax will be deemed to have been imposed on the first day on which action is taken by the organization which culminates in its ceasing to be a private foundation. See Treas. Reg. 1.507-8.

(2) If private foundation status is terminated under Section 507(a)(2), the first day

on which action is taken which culminates in its ceasing to be a private foundation shall be the date of occurrence of the willful and flagrant act (or failure to act) or the first of the series of willful repeated acts (or failures to act) giving rise to liability for Chapter 42 tax and Section 507(a)(2) tax. See Treas. Reg. 1.507-8.

(3) If private foundation status is terminated under Section 507(a)(1), the first day

on which action is taken which culminates in its ceasing to be a private foundation shall be the date on which the terminating foundation gives the notification described in section 507(a)(1). See Treas. Reg. 1.507-8.

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