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Abstract: 

Grants by foundations to federal, state, and local governments are hardly unique. Grants count as qualifying distributions for purposes of IRC § 4942 if they are for charitable purposes as described in IRC § 170(c)(1), and those purposes include the exclusively public purposes of a state, a possession of the United States, political subdivisions, the United States, or the District of Columbia. Therefore, barring some special factual twist, such a grant normally presents no problem. But what if the grantee is a governmental authority in another country? A recent series of rulings, all apparently issued to the same foundation, approve a variety of grants to foreign governments.

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