Organization qualified under section 4945(f)

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