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Special rules apply to certain foundations and trusts, which may also be subject to some or all of the general private foundation excise taxes :

• Private nonoperating foundation distributing all contributions received (sometimes referred to as a private pass-through foundation)
• Private foundation maintaining a common fund
• Nonexempt charitable trusts
• Estates in administration with charitable bequests pending
• Split-interest trusts
• Certain split interest trusts that become charitable trusts
• Foreign foundations
• Certain split-interest trusts that wind up
• Revocable trusts that become charitable trusts
• Trusts devoted to qualified conservation purposes
• Charitable trusts that support public charities (section 509(a)(3) supporting organizations)

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