The memorandum discusses the formation of a private operating foundation, the Black Art Foundation, for Leon Black's art collection. It outlines the benefits of tax deductions for art donations, the structure and operation of the foundation, and compliance with IRS regulations. The foundation would lend art to public museums and ensure no personal use of donated art. The memo also covers the foundation's control, mission statement, and estate tax benefits.
documents/EFTA01074856.pdf
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