Except as otherwise provided in Transfer to an effectively controlled foundation, a private foundation must meet the distribution requirements for any year in which it makes a section 507(b)(2) PDF transfer of all or part of its net assets to another private foundation. The transfer itself will be counted as a qualifying distribution if it meets the requirements to be considered such a distribution. However, when the transferor has disposed of all its assets, the recordkeeping requirements will not apply to any period in which it has no assets.
