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PLR Roundup: A Spotlight on Foundation Scholarships  


Author:  Katherine E. David.


Source: Volume 14, Number 06, September/October 2015 , pp.10-16(7)




Family Foundation Advisor

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Abstract: 

Ordinarily, a grant that a private foundation pays to an individual for travel, study, or similar purposes is treated as a taxable expenditure and is subject to excise tax under IRC §4945. However, a grant is not treated as a taxable expenditure if it meets the definition of a “qualified” scholarship or fellowship grant under IRC §117. This article summarizes, individually, nearly 60 recent IRS private letters ruling on programs that fund students’ tuition under sections §74, §117, and §170.

Keywords: IRC §170(b)(1)(A)(ii) schools; grants or awards under IRC §74(b)

Affiliations:  1: Strasburger & Price, LLP.

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