Excise Taxes on Excess Business Holdings

ID:
Office:
UILC:
CCA_2008092207330553
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509.02-02, 4943.00-00
Number: 200851070
Release Date: 12/19/2008
From: ---
Sent: Monday, September 22, 2008 7:33:08 AM
To: ---
Cc: ---
Subject: RE: 509(a)(3)
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I have forwarded this to my colleagues ---and ---who are more familiar with section 509(a)(3) than I am. --- mentioned that if this is a type 3 supporting organization under the Pension Protection Act of 2006, such an interest likely will be subject to section 4943 excess business holding provisions, but would still have 5 years to dispose of the interest. Also 4943 can apply to type 1 and 2 supporting organizations in certain circumstances. I still have to address your prior email and will try to this week.
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