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Abstract: 

For clients who have trouble making decisions that have permanent consequences, the adage “something is better than nothing” is good advice. It is better to have some preliminary planning in place, even with the expectation that the plan will be revisited and refined over time. And, some individuals take comfort in accomplishing pieces of their plans, even when they know that further planning, decision making, transfers, and documentation will be required. In these situations, an advisor might create a “shelf” foundation: one that has been created under state law and that has obtained a determination that it is tax-exempt under IRC §501(c)(3), but that the founder does not intend to fund or operate until a later date—which may even be after the founder’s death.

Keywords: Form 1023-EZ; dormancy; revoked exemption; PLR 20144826

Affiliations:  1: Strasburger & Price, LLP.