Real Property Transfer Agreement - South Bend Heritage Foundation - 912 W Oak Street (2)

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M I. ➢`O onstruction of Powers s Fur o§ese �. The powers enumerated in para- graphs G and H shall not be construed as corporate purposes, but the Foundation shall exercise such powers solely in furtherance of, but not in addition to, the corporate purposes stated in paragraphs A through F. J. S ecial gui.reinents and Limitations Up2 fur poses and Powers (1) S ecial Requirements. The Foundation shall make during each taxable year such distributions of income or other property as may be required at such times and in such manner as not to subject the Foundation to tax under Section 4942 of the Internal Revenue Code of 1954, as amended, or corresponding provisions of any subsequent Federal Tax laws. (2) Certain Prohibited. Practices. The Foundation is prohibited from engaging in any act of self --dealing as defined in Section 4941(d) of the Internal Revenue Code of 19 54 , as amended, or corresponding provisions of any subsequent Federal Tax law, from retaining any excess business holdings as defined in Section 4943(c) of the Internal Revenue Code of 1954, as amended, or corresponding provisions of any subsequent Federal Tax law, from making any investments in such manner as to subject the Foundation to tax under Section 4944 of the Internal Revenue Code of 1954, as amended, or corresponding provisions of any subsequent Federal Tax law, and from making any taxable expenditures as defined in Section 4945(d) of the Internal Revenue Code of 1954, as amended, or corresponding provisions of any subsequent Federal Tax law.