Community Trust and Related Corporation are Ruled a Single Entity

In PLR 201307008,the Service ruled that the trust and related corporation could be treated as a single entity and that the component funds of both the foundation and the related corporation would be treated as funds of the single entity.

The basic facts the PLR addressed are as follows: Over a century ago, a foundation was formed as a community trust.  The foundations’s distribution company formed a corporation, which was an affiliate of the foundation.  The governing documents of both entities required that they be subject to a common governing body.

See PLR 201307008-Corporation and Community Trust Treated As a Single Entity, Charitable Planning.com, Feb. 18, 2013. 

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.