A substantial contributor of the transferor foundation will be considered a substantial contributor of the transferee organization even if the individual does not meet the definition of a substantial contributor with respect to the transferee organization. With respect to the transferor foundation, a person is a substantial contributor if the person contributed or bequeathed an aggregate amount of more than $5,000 to the foundation, provided that the amount contributed is more than 2 percent of the total contributions received by the foundation before the close of the taxable year in which the contribution or bequest is received by the foundation. Return to Life Cycle of a Private Foundation
