WebAug 25, 2014 · Under Section 4943 (c) (2), a PF is permitted to hold 20 percent of the voting stock of an incorporated business enterprise, reduced by the percentage of voting stock owned by disqualified... WebUnder section 4943 (c) (6) (A) the entire 38 percent (5% + 33%) of the X voting stock shall be treated as held by a disqualified person from June 30, 1977 (the date the 33 percent interest is constructively acquired by F) until August 17, 1983 (five years after the date of distribution of the 33 percent interest to F).
26 CFR § 53.4943-10 - Business enterprise; definition.
WebMay 4, 2024 · Generally, under section 4943 of the Internal Revenue Code, the combined holdings of a private foundation and all of its disqualified persons are limited to 20 … Web26 U.S. Code § 4943 - Taxes on excess business holdings U.S. Code Notes prev next (a) Initial tax (1) Imposition There is hereby imposed on the excess business holdings of any private foundation in a business enterprise during any taxable year which ends during the … Except to the extent provided by regulation, under rules similar to the rules of section … The Secretary of the Treasury shall calculate the amount of each covered … simon said he had no idea
4943 - U.S. Code Title 26. Internal Revenue Code - Findlaw
WebJan 1, 2024 · Internal Revenue Code § 4943. Taxes on excess business holdings on Westlaw. FindLaw Codes may not reflect the most recent version of the law in your … WebFor purposes of section 4943 and the regulations thereunder, the term “sole proprietorship” means any business enterprise (as defined in paragraphs (a), (b), and (c) of this section: ( 1) Which is actually and directly owned by a private foundation, ( 2) In which the foundation has a 100 percent equity interest, and WebJan 9, 2024 · A Type II supporting organization must be supervised or controlled in connection with its supported organization (s), typically by having a majority of the directors or trustees of the supported organization (s) serve as a majority of the trustees or directors of the supporting organization. simon sachers