Foreign Foundation Held Able to Treat Assets of Foreign Investment Vehicle as Those of Disregarded Entity, With Income Subject to Excise Tax

Abstract

The IRS granted a foreign private foundation an extension of time to file an entity classification election on behalf of a disregarded entity, thereby causing the entity's income and assets to be exempt from federal income tax but with the income subject to the private foundation excise tax (Priv. Ltr. Rul. 201808010).