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Abstract: 

Two recent rulings reflect the creativity that private foundations bring to making individual grants in furtherance of their exempt purposes. In one, a foundation was able to structure an executive’s leave of absence so as to avoid its being deemed a taxable expenditure, as it normally would, under IRC §4945. In a second ruling, the service approved a travel grant under the foundation’s leadership skills program. Other PLRs include a ruling that a foundation’s posting of pledged securities was a program related investment, not a jeopardizing investment under §4944(a); and a set-aside for a construction project under Treas. Reg. Reg. §53.4942(a)-3(b)(2).

Keywords: Travel grants; pledged securities as qualifying distributions; project suitability test

Affiliations:  1: Strasburger & Price, LLP.