A.11. Jointly Funded Projects

(1) Treas. Reg. 53.4945-2(a)(3) provides that private foundations will not be treated

as lobbying by making expenditures to fund discussions with members of legislative bodies or officials of governmental bodies provided:

a. The subject of such discussions is a program which is jointly funded by the

foundation and the Government or is a new program which may be jointly funded by the foundation and the Government;

b. The discussions are undertaken for the purpose of exchanging data and

information on the subject matter of the programs; and

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c. Such discussions are not undertaken by foundation managers in order to

make any direct attempt to persuade governmental officials or employees to take positions on specific legislative issues other than such program.

(2) Similarly, a private foundation is not treated as lobbying merely by making

expenditures to fund another organization’s program upon the condition that the recipient obtain a matching support appropriation from a governmental body. See Treas. Reg. 53.4945-2(a)(3). These activities would not constitute taxable expenditures as attempts to influence legislation.