Any qualifying distribution made during the tax year will be treated as being made:
- First, out of undistributed income of the immediately preceding tax year (if the private foundation was subject to the initial excise tax for the prior tax year) to the extent thereof,
- Second, out of undistributed income for the current tax year to the extent thereof, and
- Then, out of corpus.
Distributions are taken into account in the order of time in which made.