2015 Tax Seminar (Salk Institute), La Jolla, California

Your foundation wants to go beyond its grant-making programs and increase its involvement, perhaps through leveraging your expertise, supplementing your grant-making dollars, and/or investing strategically and programmatically.  But how do you expand while still being subject to the prohibited transaction rules set out in the Internal Revenue Code?  This paper and presentation examine key issues of direct charitable activities, program-related investments, advantages and disadvantages of private operating foundations, and use of separate and subsidiary entities for related activities.