Though it may operate as a taxable entity, it will continue to be treated as a private foundation until that status is terminated under section 507. A nonoperating private foundation is a private foundation that is not a private operating foundation. A foundation manager is an officer, director, or trustee of a foundation, or an individual who has powers similar to those of officers, directors, or trustees. In the case of any act or failure to act, the term foundation manager may also include employees of the foundation who have the authority to act. An organization is controlled by a foundation or by one or more disqualified persons with respect to the foundation if any of these persons may, by combining their votes or positions of authority, require the organization to make an expenditure or prevent the organization from making an expenditure, regardless of the method of control.
Control is determined regardless of how the foundation requires the contribution to be used.