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Exempt Organizations Technical Guide›TG 62: Excise Taxes on Taxable Expenditures – IRC Section 4945›Table of Contents

A.13. Certain Expenditures by Program-Related Investment Recipients

Publication 5590 — Exempt Organizations Technical Guide TG 62: Excise Taxes on Taxable Expenditures under IRC 4945 · 2026-10-03 edition · updated 2026-10-04 · United States

(1) Any amount paid or incurred by a recipient of a program-related investment (as

defined in Treas. Reg. 53.4944-3) in connection with an appearance before, or communication with, any legislative body with respect to legislation or proposed legislation of direct interest to such recipient shall not be attributed to the grantor foundation, if:

a. The foundation does not earmark its funds to be used for any activities

described in Section 4945(d)(1); and

b. A deduction under Section 162 is allowable to the recipient for such amount.

See Treas. Reg. 53.4945-2(a)(4).

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▸Contents — Publication 5590 — Exempt Organizations Technical Guide TG 62: Excise Taxes on Taxable Expenditures under IRC 4945
Publication 5590 — Exempt Organizations Technical Guide TG 62: Excise Taxes on Taxable Expenditures under IRC 4945

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