Code of Federal Regulations Title 26. Internal Revenue § 26.1.507–4 Imposition of tax

(a) General rule.Section 507(c) imposes on each organization the private foundation status of which is terminated under section 507(a) a tax equal to the lower of:

(b) Transfers not subject to section 507(c).Private foundations which make transfers described in section 507(b)(1)(A) or (2) are not subject to the tax imposed under section 507(c) with respect to such transfers unless the provisions of section 507(a) become applicable. See §§ 1.507–1(b), 1.507–2(a)(6) and 1.507–3(d).