Читать книгу The Tax Law of Charitable Giving - Bruce Hopkins R., Bruce R. Hopkins, David Middlebrook - Страница 44

Three other categories of charitable organizations⁴⁹⁹ are treated as entities other than private foundations for purposes of the law of charitable giving. This means that contributions to these entities may be deductible up to the 50 percent limitation.⁵⁰⁰ These categories are:

1 Private operating foundations.⁵⁰¹ This type of private foundation is an organization that would be a standard private foundation but for the fact that most of its earnings and much of its assets are devoted directly to the conduct of its charitable activities.⁵⁰²

2 Conduit foundations.⁵⁰³ This type of private foundation makes timely qualifying distributions (usually grants)⁵⁰⁴ that are treated as distributions out of corpus, in an amount equal in value to all contributions received in the year involved, whether as cash or property.⁵⁰⁵

3 Common fund foundations.⁵⁰⁶ This type of private foundation pools contributions received in a common fund but allows donors to retain the right to designate annually the organizations to which the income attributable to the contributions shall be given and to direct the organizations to which the corpus of the contributions is eventually to be given.⁵⁰⁷