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

B.3. 85% Support Test

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

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(1) The 85% support test of Section 4945(f)(4) is determined on an aggregate basis

over a five-year period consisting of the current tax year and the immediately preceding four tax years. See Section 4945(f) and Treas. Reg. 53.4945-3(b)(3)(i).

(2) If an organization has completed at least one but less than four years, the support

test is determined by aggregating all the support received during the current tax year and during each preceding taxable year. See Treas. Reg. 53.49453(b)(3)(iii).

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

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