Tennessee Code Title 35. Fiduciaries and Trust Estates § 35-9-101

(1) Engaging in any act of self-dealing, as defined in § 4941(d) of the Internal Revenue Code of 1954 (26 U.S.C. § 4941(d)), that would give rise to any liability for the tax imposed by § 4941(a) of the Internal Revenue Code of 1954 (26 U.S.C. § 4941(a));

(2) Retaining any excess business holdings (as defined in § 4943(c) of the Internal Revenue Code of 195426 U.S.C. § 4943(c)), that would give rise to any liability for the tax imposed by § 4943(a) of the Internal Revenue Code of 1954 (26 U.S.C. § 4943(a));

(3) Making any investments that would jeopardize the carrying out of any of the exempt purposes of the trust, within the meaning of § 4944 of the Internal Revenue Code of 1954 (26 U.S.C. § 4944), so as to give rise to any liability for the tax imposed by § 4944(a) of the Internal Revenue Code of 1954 (26 U.S.C. § 4944(a)); or

(4) Making any taxable expenditures (as defined in § 4945(d) of the Internal Revenue Code of 1954 (26 U.S.C. § 4945(d)), that would give rise to any liability for the tax imposed by § 4945(a) of the Internal Revenue Code of 1954 (26 U.S.C. § 4945(a)); provided, that this section does not apply either to those split-interest trusts or to amounts of those split-interest trusts that are not subject to the prohibitions applicable to private foundations by reason of § 4947 of the Internal Revenue Code of 1954 (26 U.S.C. § 4947).