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Determination Letter 201531023 Released July 31, 2015 Approved Transcribed from scan

Organization qualified under section 4945(f)

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Currency note: this determination was released in 2015
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

An existing section 501(c)(3) public charity asked to be recognized as an organization described in section 4945(f). Based on the information supplied and the organization’s stated future operations, the IRS approved the request. Private foundations could make grants to the organization without those grants being treated as taxable expenditures under sections 4945(d)(2) or 4945(d)(4), as long as the organization remained described in section 4945(f).

Ruling snapshot

  • Question: Did the organization qualify as an organization described in section 4945(f)?
  • Outcome: Approved
  • Key authorities: IRC §§ 170(b)(1)(A)(vi), 501(c)(3), 509(a)(1), and 4945(f)

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
P. O. Box 2508
Cincinnati, OH 45201

Release Number: 201531023
Release Date: 7/31/2015
Date: 5/6/2015

Person to Contact - ID#:
Contact Telephone Numbers:

Employer Identification Number:

UIL: 4945.04-03
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 sections 509(a)(1) and 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).

We've sent a copy of this letter to your representative as indicated in your power of
attorney.

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,

Director, Exempt Organizations

Letter 4778 (3-2012)
Catalog Number 58221N

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