Tax Law - Recent Accomplishments

On behalf of a non-profit foundation, Robert Canter and Gary Horowitz obtained a private letter ruling from the IRS on a unique issue. Under federal tax law, a private foundation is subject to severe tax penalties if it fails to dispose of its “excess business holdings” within 5 years.  Our client, a private foundation, received a donation of stock in a closely held business but was unable to dispose of that stock within the required time period.  Although the IRS has granted very few extensions, Messrs. Canter and Horowitz submitted to the IRS a private letter ruling request for an extension of time to dispose of the foundation’s excess business holdings.  After a meeting between the IRS and our attorneys, the IRS agreed to grant the foundation the necessary extension of time, thereby preventing tax penalties from being assessed against the foundation.