Scientific conference presentation grants approved

Plain-English summary

A private foundation proposed travel grants for graduate students, postdoctoral fellows, and faculty members presenting research in a specified field at scientific conferences. Awards had separate caps for domestic and international conferences, with half paid after proof of registration and acceptance and the balance paid after attendance, submission of presentation materials, expense documentation, and an impact report. Recipients had to return unused funds or all funds if they could not attend. At least two advisory-board members would assess research quality, publication status, and the potential impact of the conference, without deriving private benefit from selections. Awards could recur only if a recipient had not received one during the prior 12 months. The IRS approved the procedures under section 4945(g)(3), so grants made as proposed would not be taxable expenditures.

Ruling snapshot

• Question: Do the proposed grants for presenting scientific research at conferences satisfy the advance-approval rules for educational grants?
• Outcome: Approved, provided the program operates as described
• Key authorities: IRC §§ 74(b), 117(a), 170(b)(1)(A)(ii), 4945(g)(3); Treas. Reg. § 53.4945-4(c)(1)

Full text (IRS public release)

Department of the Treasury Date:09/13/2023
Internal Revenue Service
Tax Exempt and Government Entities
P.O. Box 2508
Cincinnati, OH 45201

Taxpayer ID number:

Person to contact:

Name:
ID number:
Telephone:
Release Number: 202349017
Release Date: 12/8/2023
LEGEND UIL: 4945.04.04

W = Grant Program

X = Field of Study

y dollars = Grant Amount
z dollars = Grant Amount

Dear

You asked for advance approval of your educational grant procedures under Internal Revenue Code (IRC)
Section 4945(g)(3).

This approval is required because IRC Section 4945 provides for the imposition of taxes on each taxable
expenditure of a private foundation. IRC Section 4945(d)(3) provides that the term “taxable expenditure"
includes any amount paid or incurred by a private foundation as a grant to an individual for travel, study, or
similar purposes by the individual, unless the grant satisfies the advance approval requirement of IRC Section
4945(g).

Our determination

We approved your procedures for awarding educational grants. Based on the information you submitted,
and assuming you will conduct your program as proposed, we determined that your procedures for awarding
educational grants meet the requirements of IRC Section 4945(g)(3). As a result, expenditures you make
under these procedures won't be taxable.

Description of your request

Your letter indicates you will operate W, which is to promote the dissemination of X related research
worldwide through presentations at scientific conferences. W is open to any graduate student, postdoctoral
fellow or faculty member at a recognized educational institution. The recipient must present X-specific research
through oral or poster presentations.

The recipient can receive up to y dollars for domestic conferences and up to z dollars for international
conferences. One half of the awarded funds will be provided upon proof of conference registration and
acceptance of poster or oral abstract. The balance of the funds will be awarded after attendance of the
conference and submission of the presentation materials, proof of expenses, and a report highlighting the
impact of the presented work. Awards will be paid directly to the recipient and must be used for conference-
related expenses. Any unused funds must be returned. If the recipient is unable to attend the conference, they
must notify you and return any funds already paid to them.

Selection of recipients will be based on the quality of the X research, publication status of the work to be
presented (preference given to unpublished work) and the potential impact of the presentation (type and size of
Letter 4792 (Rev. 1-2022)

Catalog Number 58263T

the conference). At least two members of your advisory board will evaluate each application. No member of
your advisory board will be in a position to derive a private benefit, directly or indirectly, from the selection of
the grant recipients. The award is renewable so long as the recipient has not received an award within the
previous twelve months.

Basis for our determination

IRC Section 4945 imposes excise taxes on the taxable expenditures of private foundations. A taxable expenditure
is any amount a private foundation pays as a grant to an individual for travel, study or other similar purposes.
However, a grant that meets all the following requirements of IRC Section 4945(g) is not a taxable expenditure.

• The foundation awards the grants on an objective and nondiscriminatory basis.
• The IRS approves in advance the procedure for awarding the grant.
  The grant is:
  ~ A scholarship or fellowship subject to IRC Section 117(a) and is to be used for study at an educational
  organization described in IRC Section 170(b)(1)(A)(ii); or
• A prize or award subject to the provisions of IRC Section 74(b), if the recipient of the prize or award is
  selected from the general public; or

• To achieve a specific objective; produce a report or similar product; or improve or enhance a literary,
  artistic, musical, scientific, teaching, or other similar skill or talent of the recipient.
  To receive approval of its educational grant procedures, Treasury Regulation Section 53.4945-4(c)(1) requires
  that a private foundation show:

• The grant procedure includes an objective and nondiscriminatory selection process.
  ¢ The grant procedure results in the recipients performing the activities the grants were intended to finance.

• The foundation plans to obtain reports to determine whether the recipients have performed the activities that
  the grants were intended to finance.

Other conditions that apply to this determination
¢ This determination only covers the grant program described above. This approval will apply to
succeeding grant programs only if their standards and procedures don't differ significantly from those
described in your original request.

• This determination applies only to you. It may not be cited as a precedent.

• You cannot rely on the conclusions in this letter if the facts you provided have changed substantially.
  You must report any significant changes to your program to the IRS at:
  Internal Revenue Service
  Exempt Organizations Determinations
  TE/GE Stop 31A Team 105
  P.O. Box 12192
  Covington, KY 41012-0192
  ¢ You can't award grants to your creators, officers, directors, trustees, foundation managers, or
  members of selection committees or their relatives.
  ¢ All funds distributed to individuals must be made on a charitable basis and further the purposes of your
  organization. You cannot award grants for a purpose that is inconsistent with IRC Section 170(c)(2)(B).
  ° You should keep adequate records and case histories so that you can substantiate your grant
  distributions with the IRS if necessary.
  We'll make this determination letter available for public inspection after deleting personally identifiable

Letter 4792 (Rev. 1-2022)
Catalog Number 58263T

information, as required by IRC Section 6110. We've enclosed Letter 437, Notice of Intention to Disclose -
Rulings, and a copy of the letter that shows our proposed deletions.
° If you disagree with our proposed deletions, follow the instructions in the Letter 437 on how to notify us.

• If you agree with our deletions, you don't need to take any further action.

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

If you have questions, you can contact the person shown at the top of this letter.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:

Letter 4792 (Rev. 1-2022)
Catalog Number 58263T