Exempt Organizations Technical Guide›TG 62: Excise Taxes on Taxable Expenditures – IRC Section 4945›Table of Contents
D.6. Pre-grant Inquiry Requirement Section 4945(h)(1)
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) Before a private foundation makes a grant to an organization subject to
expenditure responsibility, it should conduct a limited pre-grant inquiry to ensure that the grant will be used for proper purposes. See Treas. Reg. 53.49455(b)(2)(i).
(2) The pre-grant inquiry should include:
a. The identity, prior history, and experience of the grantee organization and its
managers;
b. Whether the grantee has a history of compliance or noncompliance with the
terms of previous grants, and any knowledge concerning the management, activities, and practices of the grantee organization.
(3) The scope of the pre-grant inquiry will vary in each case depending on:
a. The size and purpose of the grant;
b. The period over which it will be paid; and
c. Any prior experience the grantor has had with the grantee. See Treas. Reg.
53.4945-5(b)(2)(i).
(4) Ordinarily, no further pre-grant inquiry is necessary where a grantee has properly
used all prior grants and filed the required reports. See Treas. Reg. 53.49455(b)(2)(ii) for examples illustrating the pre-grant inquiry rule.
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