If an organization's private foundation status has been terminated by transferring its assets to, or operating as, a public charity, and 1) The organization does not continue at all times thereafter to meet the requirements of section 509(a)(1), (2), or (3) (and is, therefore, no longer excluded from the definition of a private foundation), and 2) The status of the organization as a private foundation is thereafter terminated under section 507(a), Then for determining the private foundation termination tax, the combined tax benefit resulting from section 501(c)(3) status will be figured only from the date on which the organization again becomes a private foundation. Return to Life Cycle of a Private Foundation
