Transfers to Organizations not Described in Sections 501(c)(3) or 4947(a)(1)

(1) In general, a transfer of assets by a private foundation to an organization not

described in Section 501(c)(3) or treated as described in Section 501(c)(3) under Section 4947(a)(1) constitutes a taxable expenditure under Section 4945(d)(5). If such a transfer is made and, in order to correct the taxable expenditure, later is transferred to a private foundation, Section 507(b)(2) and Treas. Reg. 1.507-3(a) would be applicable as though the transfer had been made directly to the private foundation.