Public charity recognized as a section 4945(f) exempt operating foundation

Number

201621016

Outcome

Approved

Document type

Determination Letter

IRS subject

Educational Organizations

Topics

Tax-exempt organizations

Code sections

§ 170, § 501, § 509, § 4945

Ruling dated

February 25, 2016

Publicly released

May 20, 2016

Source

View Official PDF

Apply this to your situation

This page covers one taxpayer's determination, issued in 2016, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

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 organization already recognized as a section 501(c)(3) public charity asked to be recognized under section 4945(f). Based on the supplied information and the organization’s proposed operations, the IRS determined that it qualified as an exempt operating foundation under that section. As long as it continues to meet section 4945(f), grants made to it by private foundations will not be taxable expenditures under sections 4945(d)(2) or 4945(d)(4).

Ruling snapshot

Question: Does the public charity qualify as an exempt operating foundation under § 4945(f)?
Outcome: Approved.
Key authorities: IRC §§ 170(b)(1)(A)(vi), 501(c)(3), 509(a)(1), 4945(d), 4945(f).

Full text (IRS public release)

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

Release Number: 201621016

Date: 5/20/2016

Date: February 25, 2016

UIL Code: 50103-08 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) 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).

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,

Jeffrey I. Cooper
Director, Exempt Organizations
Rulings and Agreements

Letter 4778 (3-2012)
Catalog Number 58221N

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