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The Internal Revenue Service (IRS) issued on September 3, 2021 Revenue Procedure 2021-40 (2021-40), which stated that the IRS will place a temporary halt on issuing letter rulings or determination letters in relation to whether certain transactions are self-dealing within the meaning of Section 4941(d) of the Internal Revenue Code (the Code).

While analyzing critical issues to explore in each issue of Cyber Roundup and working with our clients on their cyber challenges, I am continually astonished at the schemes bad actors conceive of to disrupt business, the economy and people’s everyday activities.

Acts of self-dealing come in many forms, and it is vital that foundation managers and board members are mindful of the different types of self-dealing prohibitions and the potential consequences to the foundation and the individuals involved in the act.