Essentially, under section 4941 of the Internal Revenue Code and related regulations, a private foundation’s disqualified persons — those who control and fund the foundation — are prohibited from direct and indirect financial transactions with the foundation unless a specific exception applies. The term “disqualified person” includes the following: - a substantial contributor to the foundation; - foundation managers (officers, directors, trustees, or person with similar powers); - any owner of more than 20 percent of the combined voting power of a corporation, profits interest of a partnership, or beneficial interest in a trust/association which is a substantial contributor; - family members (spouses, ancestors, children, grandchildren, great-grandchildren, and spouses of children, grandchildren and great-grandchildren) of an individual described above; - controlled entities (e.g., a corporation of which disqualified persons own more than 35 percent of the combined voting power); and -...