related person

(2) Substantial contributor (A) Definition For purposes of paragraph (1), the term “substantial contributor” means any person who contributed or bequeathed an aggregate amount of more than $5,000 to the private foundation, if such amount is more than 2 percent of the total contributions and bequests received by the foundation before the close of the taxable year of the foundation in which the contribution or bequest is received by the foundation from such person. In the case of a trust, the term “substantial contributor” also means the creator of the trust. (B) Special rules For purposes of subparagraph (A)— (i) each contribution or bequest shall be valued at fair market value on the date it was received, (ii) in the case of a foundation which is in existence on October 9, 1969 , all contributions and bequests received on or before such date shall be treated (except for purposes of clause (i)) as if received on such date, (iii) an individual shall be treated as making all contributions and bequests made by his spouse, and (iv) any person who is a substantial contributor on any date shall remain a substantial contributor for all subsequent periods. (C) Person ceases to be substantial contributor in certain cases (i) In general A person shall cease to be treated as a substantial contributor with respect to any private foundation as of the close of any taxable year of such foundation if— (I) during the 10-year period ending at the close of such taxable year such person (and all related persons) have not made any contribution to such private foundation, (II) at no time during such 10-year period was such person (or any related person) a foundation manager of such private foundation, and (III) the aggregate contributions made by such person (and related persons) are determined by the Secretary to be insignificant when compared to the aggregate amount of contributions to such foundation by one other person. For purposes of subclause (III), appreciation on contributions while held by the foundation shall be taken into account. (ii) Related person For purposes of clause (i), the term “related person” means, with respect to any person, any other person who would be a disqualified person (within the meaning of section 4946 ) by reason of his relationship to such person. In the case of a contributor which is a corporation, the term also includes any officer or director of such corporation.

Source

26 USC § 507(d)(2)


Scoping language

None identified. Default scope is assumed to be the entire title.
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