Indirect Loans Between a Private Foundation and a Disqualified Person Are on the IRS’ Radar
Code Section 4941(d)(1)(B) treats lending transactions between a private foundation and disqualified person as an act of self-dealing (although an interest-free loan by the disqualified person to the private foundation is not self-dealing) subject to an excise tax. What happens if the private foundation owns an interest in an entity, and that entity holds a promissory note of a disqualified person? Does this avoid self-dealing?
In Rev. Proc. 2021-40. . .