IRS pre-approves a foundation's travel and workshop grants for educators in an invention-education network

Plain-English summary

A private foundation runs a program that supports a network of educators,
nonprofit leaders, and researchers working in a specialized field of education.
It asked the IRS to approve, in advance, the procedures for grants that pay
travel and meeting expenses so network members can attend educational
gatherings (conferences) and put on small-group workshops. Unlike a plain
scholarship, these are "educational grants" reviewed under IRC Section
4945(g)(3), which covers grants to achieve a specific objective or to improve a
skill or talent. Under IRC Section 4945, a private foundation's grants to
individuals are "taxable expenditures" that trigger excise tax unless the IRS
approves the grant-making procedures in advance. The foundation described an
objective, nondiscriminatory selection process (based on financial need and
engagement), limited eligibility to members of the network, and committed to
collect reports on how the funds were used. The IRS found the procedures meet
the requirements of Section 4945(g)(3) and Treasury Regulation Section
53.4945-4(c)(1) and approved them, so the grants are not taxable expenditures.
This is a routine advance-approval letter (Letter 4792) that binds only this
foundation.

Ruling snapshot

• Question: Do the foundation's travel and workshop grant procedures qualify for advance approval under IRC Section 4945(g)(3)?
• Outcome: approved
• Key authorities: IRC § 4945(d)(3), (g)(3); § 117(a); § 74(b); § 170(b)(1)(A)(ii); Treas. Reg. § 53.4945-4(c)(1)

Full text (IRS public release)

Department of the Treasury                       Date:
Internal Revenue Service                         01/07/2026
IRS Tax Exempt and Government Entities           Taxpayer ID number:

                                                 Person to contact:
                                                 Name:
                                                 ID number:
                                                 Telephone:

Release Number: 202614033
Release Date: 4/3/2026

LEGEND                                           UIL: 4945.04-04
B = Program
C = Name
D = Type
E = Network
F = Range
G = Conference
H = Workshops
j dollars = Dollars
K dollars = Dollars
L = Number
m dollars = Dollars
u dollars = Dollars
O = Number
P = Number

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 B.

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

You have helped develop the C platform, designed to share, learn, and build community; to create awareness
and communicate D education’s impact; and to facilitate connections and collaborations that broaden the D
education ecosystem. You also helped develop the E, a coalition of F educators, nonprofit leaders, researchers,
government agencies, funders, and others who are building and supporting the field of D education. Through
your C community, E members can reinvigorate their teaching practices through mentorship, peer support, and
professional development that will help them to feel confident and enthusiastic about integrating D education
into their curriculums. The purpose of B is to provide travel support and support for meeting-related expenses to
members of the E to allow them to participate in educational convenings focused on D education, thereby
improving and enhancing their educational capabilities and skills and, by extension, the educational capacities
and skills of their broader respective networks.

Through B you will make grants to individuals to allow them to participate in or to put on C educational
convenings. Eligible educational convenings include your own G and also H held by E members. Your G
generally includes, but is not limited to, educational sessions on maximizing D education opportunities in and
out of the classroom, developing an D education ecosystem, how to teach students to be problem solvers, and
the need for expanding access to D education. The H allow small groups of E members to further pursue project
ideas that support field-level growth and sustainability in invention education.

For your G, you anticipate that the maximum amount of a grant could be up to approximately j dollars and the
average amount would be approximately k dollars, with specific amounts dependent on locations of travel, costs
of lodging, and other relevant factors. You anticipate that you could award L grants in any given year,
dependent on the number of individuals applying for support and the available resources for the program.

For your G, you anticipate that the maximum amount of a grant could be up to m dollars and the average amount
would be approximately n dollars, depending on the location of travel, number of individuals in the group who
are applying, and the costs and purposes of the specific workshop-related expenses. You could award O grants
in any given year.

You may publicize the availability of G grants through a variety of means, including email newsletters
communications, website or direct emails to E members. You may publicize the availability of H grants through
a variety means, including email newsletter communications to E members or direct emails to attendees of the
recent G. You will seek to reach as many members of the E as reasonably possible.

Any person who is participating in C activities may become a member of the E, and any member of the E is
eligible to apply for a grant to attend G. Anyone who has attended a recent G and wishes to thereafter continue
to pursue a collaborative D-education-related project with other E members may apply for a grant to attend a
H. You estimate there are approximately P members of the E, but you anticipate this number to continue to
grow. You limit your support to members of the E to ensure that the group from which grantees are selected is
reasonably related to the purposes of the grants and to advance D education.

E members who are interested in attending an upcoming G and who wish to seek travel support must submit an
application providing (1) demographic information, (2) a description of their educational goals, (3) the purposes
for attending G. You evaluate the applications based on criteria including financial need and level of
engagement in E activities. Additionally, you may prioritize support to educators and students over other E
professionals based on the convening goals.

E members who have attended a recent G and who then wish to seek support to conduct or attend H are also
required to complete an application form. Small groups of people (generally between three (3) to fifteen (15))

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

apply together, identifying each person in the working group and their organization name and identify one
group member who serve as lead. In the application, applicants are required to propose the specific D-
education-related initiative that they are seeking to advance, the educational goals of such initiative/project, the
problem they want to solve, and why they believe their ideas present a viable solution to the topic challenge.
Lastly, applicant for both G and H must indicate whether they have received prior grants from you and must
confirm that they are not related through family or business to any of your director, officer, or staff person.

Selection of grant recipients will occur on a convening-by convening basis and will be based on the responses
submitted by applicant. You review application as they are submitted, and consider both the stated financial
need, the reasonableness of costs for which support is requested, the specific educational purpose of the
convening, as well as the grantee’s potential/ability to achieve or advance the educational and scientific
outcomes and goals described in the application. Because each grant will be specific to a particular convening,
there is no process in place for renewal of a grant. However, an individual who has received a grant in the past
is not prohibited from applying to receive a subsequent grant if they continue to meet the requirements for
eligibility and selection.

The terms and conditions of each grant will be contained in a letter agreement with the selected recipient(s) that
limits the use of the funds to those described in the application. Following the completion of a grant, grantees
will be required to furnish to you a summary report describing the use of the grant funds and the grantee’s
progress toward achieving the purposes of the convening. The summary reports for H must also outline key
takeaways and next steps for the group and the project, along with the final expense budget tracking all actual
expenses. You will independently verify the grantee’s attendance at the convening, when possible.

At the present time and for the foreseeable future, you anticipate that selections will be made by your staff who
have been delegated the responsibility by your Board of Directors, rather than by a selection committee.
However, you may consider establishing a selection committee that would be made up of your staff as well as
members of the E, members of other foundations, or members of your advisory committee. All selection
committee members would be determined by you, and decisions of the selection committee would be subject to
your final approval.

You represent that you will complete the following:

• Arrange to receive and review grantee reports annually and upon completion of the purpose for which the
grant was awarded,

• Investigate diversion of funds from their intended purposes,

• Take all reasonable and appropriate steps to recover the diverted funds and ensure other grant funds held
by a grantee are used for their intended purposes, and

• Withhold further payments to grantees until you obtain grantees’ assurances that future diversions will not
occur and that grantees will take extraordinary precautions to prevent future diversion from occurring.

You also represent that you will:
• Maintain all records relating to individual grants including information obtained to evaluate grantees,
• Identify a grantee is a disqualified person,
• Establish the amount and purpose of each grant, and
• Establish that you undertook the supervision and investigation of grants described above.

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.

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

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.

• The effective date of our approval is , which is the date your request was submitted.

• 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
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.

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

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 437

Letter 4792 (Rev, 1-2022}
Catalog Number 58263T