Principal Issues: Whether the Canadian Butterfly Transactions, as described below, in the context of a cross-border butterfly, meet legislative and administrative requirements?
Position: Transactions meet requirements.
Reasons: Consistent with law and administrative requirements.
Submitted by narmstrong on Mon, 04/06/2020 - 03:07
incurring indebtedness to make donations is not excluded
Does indebtedness incurred by a private foundation to make payments to qualified donees constitute a “debt incurred in the course of...
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Principal Issues: Can a private foundation borrow to make gifts to qualified donees?
Position: No.
Reasons: 149.1(4)(d). Gifts made in charitable activities carried on by a private foundation are mutually exclusive from gifts made to qualified donees.
