Contributions to a private nonoperating founda­tion may qualify for the benefit of the 50 percent contri­bution deduction limit, and donors may deduct the full value of appreciated property, if the pri­vate nonoperating foundation:

1. Distributes an amount equal in value to 100 percent of all contributions received in the tax year by the 15th day of the 3rd month after the close of its tax year,
2. Has no remaining undistributed income for the year, and
3. Distributes only qualifying distributions that are treated as distributions out of corpus.

Qualifying distributions cannot be made to:

1. An organization controlled directly or indi­rectly by the foundation or by one or more disqualified persons, or
2. A private foundation that is not an operat­ing foundation.

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