Below Market Rate Loan to Publicly Traded Company

X is a business enterprise which is financially secure and the stock of which is listed and traded on a national exchange. Y, a private foundation, makes a loan to X at an interest rate below the market rate in order to induce X to establish a new plant in a deteriorated urban area which, because of the high risks involved, X would be unwilling to establish absent such inducement.

The loan is made pursuant to a program run by Y to enhance the economic development of the area by, for example, providing employment opportunities for low-income persons at the new plant, and no significant purpose involves the production of income or the appreciation of property.

The loan significantly furthers the accomplishment of Y's exempt activities and would not have been made but for such relationship between the loan and Y's exempt activities. Accordingly, even though X is large and established, the investment is program-related.

This is an illustration modified from examples provided by the Internal Revenue Service. It is not a legal opinion on the tax treatment of any specific agreement between a private foundation and other entity.




Social Entrepreneurship
Spotlight



Youths in the Middle East Address Unemployment By Creating New Businesses


Youths in the Middle East Address Unemployment By Creating New Businesses

Youths in the Middle East deal with the world’s social problems such as high youth unemployment rates. As a solution, some are creating new businesses with a social purpose, such as tackling environmental issues, illiteracy or health, while also spurring job creation.




Nonprofit Jobs in West Virginia

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Federal Government Grant and Assistance Programs



Edited by: Michael Saunders

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