PLR Roundup: A Spotlight on Foundation Scholarships
Author: Katherine E. David.
Source: Volume 14, Number 06, September/October 2015 , pp.10-16(7)
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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.