Delaware Code § 8-127

Private foundation; powers and duties
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A corporation of this State which is a private foundation under the United States internal revenue laws and whose certificate of
incorporation does not expressly provide that this section shall not apply to it is required to act or to refrain from acting so as not to subject
itself to the taxes imposed by 26 U.S.C. § 4941 (relating to taxes on self-dealing), § 4942 (relating to taxes on failure to distribute income),

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