The document discusses the implications of investments by private foundations, private colleges and universities, and qualified retirement plans in a partnership. It highlights the excise taxes applicable to private foundations if investments jeopardize their exempt purposes, the need for annual distributions, and the potential classification of partnership interests as nonfunctionally related assets. It also covers the 'excess business holdings' provisions and the tax on net investment income for private colleges and universities. Additionally, it advises qualified retirement plans to consult legal counsel regarding ERISA implications.
doj/DataSet10/EFTA01384699.pdf
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