IRS recognizes an organization under IRC § 4945(f)

Plain-English summary

The IRS recognized an organization as exempt from federal income tax under IRC § 501(a) because it qualifies under § 501(c)(3). The IRS also determined that the organization is not a private foundation because it qualifies under § 170(b)(1)(A)(vi). The organization was recognized under § 4945(f), so grants to it by private foundations will not be treated as taxable expenditures under §§ 4945(d)(2) or 4945(d)(4), as long as it continues to qualify under § 4945(f).

Ruling snapshot

• Question: Does the organization qualify under IRC § 4945(f) so that grants from private foundations are not taxable expenditures?
• Outcome: The organization was recognized under IRC § 4945(f).
• Key authorities: IRC §§ 170, 4945, and 501

Full text (IRS public release)

Internal Revenue Service Department of the Treasury

P. O. Box 2508
Cincinnati, OH 45201

Release Number: 201305014
Release Date: 2/1/2013

Date: November 7, 2012

UIL Code: 4945-0400

Person to Contact - ID#:
Contact Telephone Numbers:

Employer Identification Number:

Dear

This letter is in response to your request to be recognized as an organization described in section 4945(f) of the Internal Revenue Code.

The Internal Revenue Service has recognized you as an organization exempt from federal income tax under section 501(a) of the Code because you are an organization described in section 501(c)(3). In addition, you are not a private foundation because you are described in section(s) 170(b)(1)(A)(vi) of the Code.

Based upon the information supplied, and assuming your operations will be as stated in your request, we’ve determined that you are an organization described in section 4945(f) of the Code. Grants made to you by private foundations will not be treated as taxable expenditures under sections 4945(d)(2) or 4945(d)(4) of the Code as long as you are described in section 4945(f).

If you have any questions regarding this matter, please contact the person whose name and telephone number are shown in the heading of this letter.

Sincerely,

Holly O. Paz
Director, Exempt Organizations
Rulings and Agreements

Letter 4778 (3-2012)
Catalog Number 58221N