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FUNDAMENTAL CONCEPTSor business leagues (trade, business, or professional associations), 430 as long as thesupported organization (or organizations) meets the one-third support test of therules concerning the service-provider type of publicly supported organization. 431A supporting organization must not be controlled directly or indirectly byone or more disqualified persons (other than foundation managers), excludingpublic charitable organizations. 432(b) Other Organizations That Are Not Treated as Private FoundationsThree other categories of charitable organizations 433 are treated as entities otherthan private foundations for purposes of the law of charitable giving. Thismeans that contributions to these entities may be deductible up to the 50 percentlimitation. 434 These categories are:• Private operating foundations. 435 This type of private foundation is an organizationthat would be a standard private foundation but for the fact thatmost of its earnings and much of its assets are devoted directly to the conductof its charitable activities. 436• Conduit foundations. 437 This type of private foundation timely makes qualifyingdistributions (usually, grants) 438 that are treated as distributions outof corpus, in an amount equal in value to all contributions received in theyear involved, whether as cash or property. 439• Common fund foundations. 440 This type of private foundation pools contributionsreceived in a common fund but allows donors to retain the rightto designate annually the organizations to which the income attributableto the contributions shall be given and to direct the organizations towhich the corpus of the contributions is eventually to be given. 441(c) Private FoundationsA private foundation, then, is a charitable organization 442 that is not one of the foregoingtypes of charitable organizations. It is essentially a charitable organization430 That is, organizations that are tax-exempt by reason of IRC § 501(c)(6). See Tax-Exempt Organizations ch. 13.431 IRC § 509(a)(3), last sentence; Reg. § 1.509(a)-4(k).432 IRC § 509(a)(3)(C); Reg. § 1.509(a)-4(a)(4). These rules are discussed in Tax-Exempt Organizations § 11.3.433 That is, organizations that are described in IRC § 501(c)(3).434 See § 7.5(a), text accompanied by note 42.435 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(E)(i).436 IRC § 4942(j)(3). The rules concerning private operating foundations are discussed in Private Foundations §3.1.437 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(E)(ii).438 See Private Foundations § 6.5.439 The rules concerning conduit foundations are discussed in Private Foundations § 3.2. For this tax treatmentto occur, the donee private foundation must make an election (Reg. § 1.170A-9(g)(2)(v)) to treat the qualifyingdistributions as distributions out of corpus, so as to substantiate the larger charitable deductions. In a situationin which the election was not made, because the foundation was unaware of it (despite the involvementof professional tax advisors), the IRS exercised its discretionary authority (Reg. § 301.9100-3) to grant an extensionof time to make this election. Priv. Ltr. Rul. 200311033.440 IRC §§ 170(b)(1)(A)(vii) and 170(b)(1)(E)(iii).441 The rules concerning common fund foundations are discussed in Private Foundations § 3.3.442 That is, an organization described in IRC § 501(c)(3). 114