C.8. Grants Made on an Objective and Nondiscriminatory Basis

(1) For a foundation to establish that its grants to individuals are made on an

objective and nondiscriminatory basis, the grants must be awarded in accordance with a program that is consistent with:

a. The existence of the private foundation’s exempt status under Section

501(c)(3);

b. The allowance of deductions to individuals under Section 170 for

contributions to the grantor private foundation; and

c. Specific rules on establishing a pool of potential grantees, selection criteria,

and the individuals making the selection. See Treas. Reg. 53.4945-4(b)(1).

(2) The first and second requirements are self-explanatory. The third requirement is

discussed below.