Grants to Individuals

Department of the Treasury
Internal Revenue Service
IRS
Tax Exempt and Government Entities
P.O. Box 2508
Cincinnati, OH 45201
Release Number: 202505026
Release Date: 1/31/2025
LEGEND
B = Location
C- State d dollars = Amount e dollars "" Amount f dollars = Amount
Dear
Date:
11/07/2024
Taxpayer ID number:
Person to contact:
UIL: 4945 .04-04
You asked for advance approval of your scholarship procedures under Internal Revenue Code (IRC) Section 4945(g)( 1 ). You requested approval of your scholarship program to fund the education of certain qualifying students.
This approval is required because IRC Section 4945 provides for the imposition of taxes on each taxable expenditure of a private foundation. IRC Section 4945(d)(3) provides that the term "taxable expenditure" includes any amount paid or incurred by a private foundation as a grant to an individual for travel, study, or similar purposes by the individual, unless the grant satisfies the advance approval requirement of IRC Section 4945(g).
Our determination
We approved your procedures for awarding scholarships. Based on the information you submitted, and assuming you will conduct your program as proposed, we determined that your procedures for awarding scholarships meet the requirements of IRC Section 4945(g)( I). As a result, expenditures you make under these procedures won't be taxable.
Additionally, awards made under these procedures are scholarship or fellowship grants and are not taxable to the recipients if they use them for qualified tuition and related expenses (subject to the limitations provided in IRC Section I I 7(b)).
Description of your request
Your letter indicates you will operate a scholarship program in order to honor students in C by helping them get a strong start after high school. The scholarships will be awarded to deserving students to earn a degree from a four-year university or college. Under your program, you will offer scholarships through local high schools and colleges in the B.
You will award at least d dollars in total awards through a combination of e and f dollar awards. The scholarship amount will vary based on a recipient's area of interest, academic and extracurricular
Letter 4792 (Rev. 1-2022)
Catalog Number 58263T