Before creating Berkshire Hathaway's owner-directed policy of social responsibility, Berkshire Hathaway requested an IRS ruling that its

Question:

Before creating Berkshire Hathaway's "owner-directed" policy of social responsibility, Berkshire Hathaway requested an IRS ruling that its decision to empower shareholders would not result in them incurring a tax bill. Can you discern why Berkshire Hathaway had these concerns?