Alexander Reid Comments on Change in IRS Policy Involving Foundations and LLC Transactions

News / September 7, 2021

Partner Alexander Reid is quoted in an article published on Sept. 7, 2021, by Tax Notes. The article “IRS Adds Transaction Involving Foundations and LLCs to No-Rule List” reports on the IRS suspension of letter rulings on the possible self-dealing consequences of a type of transaction involving private foundation ownership of limited liability company interests.

Reid told the publication that the change is a significant development for private foundations who would customarily seek IRS approval for such LLC arrangements. With the IRS now foreclosing that option with its no-rule position, he said, “practically speaking, this means that practitioners are left to go it alone as a matter of opinion practice.”

Read the article (registration required).