Exempt Organizations Technical Guide›TG 62: Excise Taxes on Taxable Expenditures – IRC Section 4945›Table of Contents
B.5. Section 4945(d)(2) and Grants to Public Charities
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) A grant awarded by a private foundation to a public charity described in Section
509(a)(1), (2), or (3) is not a taxable expenditure described in Section 4945(d)(2) if the award is not earmarked for use to influence the outcome of a specific
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election or carry on any voter registration drive and if there is no oral or written agreement whereby the private foundation may cause the recipient to engage in the aforementioned activities or to select the recipient to which the grant is to be devoted.
(2) A grant is earmarked if the grant is given pursuant to an oral or written agreement
that it will be used for specific purposes. See Treas. Reg. 53.4945-2(a)(5)(i).
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