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. . .

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