Whenever a private foundation makes a section 507(b)(2) transfer of all or part of its net assets to another private foundation, the applicable time period described in excess business holdings will include the respective holding periods of both the transferor and the transferee. Except as otherwise provided in transfer to an effectively controlled foundation, the provisions relating to taxable expenditures will not apply to the transferee or to the transferor for any expenditure responsibility grants made by the transferor during any period in which the transferor has no assets. However, the information reporting requirements relating to taxable expenditures remain in effect. Return to life cycle of a private foundation
