The foundation satisfies the cash distribution test if:
The specific project for which the amount is set aside will not be completed before the end of the tax year in which the set-aside is made,
The foundation actually distributes for exempt purposes, in cash or its equivalent, the start-up period minimum amount during the foundation's start-up period, and
The foundation actually distributes the full-payment period minimum amount in each tax year of the foundation's full-payment period.
New foundations may find the cash distribution test useful as they assess how much they will actually distribute for start-up projects.