Renewed Push for Universal Charitable Deduction
14 Mar 2023
Private Foundation Exempt Under 501(c)(3)
Private foundations fund charitable work through grants, facing strict IRS rules on payouts, self-dealing, and annual compliance reporting.
Funded primarily by a single individual, family, or corporation, these organizations provide critical grants and resources that power the nonprofit sector. But foundations operate under a unique—and often complex—regulatory framework that includes excise taxes, payout requirements, and strict prohibitions on self-dealing. At For Purpose Law Group (FPLG), we partner with private foundations nationwide to provide legal counsel that ensures compliance, protects donor intent, and sustains philanthropic impact across generations.
Formation & Structuring
Establishing a private foundation requires careful planning and attention to long-term goals. FPLG assists clients with incorporation, drafting compliant bylaws and governance documents, and securing 501(c)(3) recognition from the IRS. We also guide founders through decisions about funding, board composition, governance structures, and operational models—ensuring that the foundation is built to achieve philanthropic objectives while remaining fully compliant.
Governance & Self-Dealing Rules
Private foundations face heightened scrutiny around board conduct and transactions with insiders. FPLG advises directors and officers on fiduciary duties and provides training on avoiding self-dealing, excess business holdings, and other prohibited activities. We also assist with developing conflict-of-interest policies and governance best practices to help boards manage risk and uphold the integrity of the foundation.
Grantmaking & Charitable Distributions
Private foundations must meet annual payout requirements and comply with strict rules on grantmaking—particularly when making international grants or supporting non-charitable entities. FPLG guides foundations in structuring grants, drafting expenditure responsibility agreements, and documenting distributions to meet IRS requirements. Our counsel helps ensure that every grant advances mission while meeting compliance standards.
Compliance, Taxes & Long-Term Stewardship
From the 1.39% excise tax on net investment income to reporting on Form 990-PF, private foundations face a complex tax and compliance landscape. FPLG assists with tax reporting, compliance reviews, and audits, while also advising on succession planning and legacy strategies to sustain philanthropic goals over time. With our support, foundations can remain compliant, reduce risk, and preserve their ability to create lasting impact.
Why Clients Choose FPLG
Our Mission
FPLG's mission is to empower changemakers by providing team-based, client-focused, and proactive legal expertise—delivering the counsel leaders need to build strong, compliant, and resilient organizations.
Our Vision
To ensure every nonprofit leader in the United States is supported by expert, values-driven counsel—equipping them to lead with confidence, sustain their organizations, and maximize their impact. By equipping leaders to govern with confidence, sustain healthy organizations, and maximize their impact, we envision a sector where purpose-driven work thrives and communities flourish.
Our Values
We are defined by six core values that guide every client relationship: Proactive Resourcefulness, Compassionate Communication, Uncompromising Authenticity, Unapologetic Expertise, Building Community, and Inclusive Teamwork. Together, these principles shape how we serve nonprofit leaders—combining excellence with purpose to strengthen organizations and amplify impact.
