A functionally related business is: A trade or business the conduct of which is substantially related (aside from the mere provision of funds for the exempt purpose) to the exercise or performance by the private foundation of its charitable, educational or other purpose or function constituting the basis for its exemption, A trade or business in which substantially all the work is performed for the foundation without compensation, A business carried on by the foundation primarily for the convenience of its members, students, patients, officers or employees (such as a cafeteria operated by a museum for the convenience of its members, employees and visitors), A business that consists of the selling of merchandise, substantially all of which has been received by the foundation as gifts or contributions, or An activity carried on within a larger combination of similar activities or within a larger complex of other endeavors that is related to the exempt purposes of the foundation (other than the need to simply provide funds for these purposes). Return to Life Cycle of a Private Foundation
