Exempt Organizations Technical Guide›TG 62: Excise Taxes on Taxable Expenditures – IRC Section 4945›Table of Contents
B.6. Joint and Several Liability, and Limits on Liability of Foundation Managers
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) If more than one foundation manager is liable for the first tier tax imposed under
Section 4945(a)(2) or the second tier tax under Section 4944(b)(2), all foundation managers are jointly and severally liable for the tax imposed under each provision with respect to any one taxable expenditure. See Section 4945(c)(1) and Treas. Reg. 53.4945-1(c)(1).
(2) The maximum aggregate amount of tax all participating foundation managers are
liable for with respect to any one taxable expenditure is $10,000 under the first tier tax of Section 4945(a)(2) and $20,000 under the second tier tax of Section 4945(b)(2). See Section 4945(c)(2).
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