Tax Planning and Compliance for Tax-Exempt Organizations, 6th Edition

CHAPTER 17Taxable Expenditures: IRC §4945

• 17.1 Lobbying
  • (a) Germane Lobbying
  • (b) Nonpartisan Study of Social Issues
  • (c) Grants to Public Charities that Lobby
  • (d) Summary of Permissible Activity
• 17.2 Voter Registration Drives
• 17.3 Grants to Individuals
  • (a) Meaning of “Travel, Study, or Other Purposes”
  • (b) Compensatory Payments
  • (c) Food, Shelter, and Aid for the Poor and Distressed
  • (d) Designing an Individual Grant Program
  • (e) Company Scholarship Plans
  • (f) Seeking Approval
  • (g) Individual Grant Intermediaries
• 17.4 Grants to Public Charities
  • (a) Proof of Public Status
  • (b) No IRS Exempt Status or Letter
  • (c) The Reliance Issue
  • (d) Earmarked Grants
• 17.5 Grants to Foreign Organizations
  • (a) Recognition of U.S. Public Status
  • (b) Equivalency Procedure
  • (c) Expenditure Responsibility Route
• 17.6 Expenditure Responsibility Grants
  • (a) Pre-Grant Inquiry
  • (b) Grant Terms
  • (c) Grantee Reports
  • (d) Reporting to the IRS
  • (e) Grant Diversions
• 17.7 Noncharitable Expenditures
• 17.8 Excise Taxes Payable
• Appendix 17–1: Examples of Emergency, Hardship Grant Application, Church and Foreign Equivalency Grants

In response to abuses uncovered by the Filer Commission and reported to the Congress,¹ a sanction was added to the Internal Revenue Code (IRC) to limit the manner in which a private foundation (PF) can spend its money to accomplish its exempt purpose. Whereas other types of exempt organizations can engage in some amount of nonexempt activity without losing their exempt status, private ...