Charitable trusts that qualify under section 509(a)(3) (as supporting organizations of public charities) are not private foundations and, thus, are not subject to the taxes and restrictions that apply to private foundations. In determining if it qualifies under section 509(a)(3), a charitable trust will be treated as if organized on the day it first becomes subject to section 4947(a)(1). The previous relationship between the charitable trust and the organizations it benefits or supports may be considered. The charitable trust may obtain recognition of its status as a section 509(a)(3) organization by requesting a ruling from the Internal Revenue Service. Return to Life Cycle of a Private Foundation
