Qualifying Distributions of Private Foundations: Treatment of Contribution Used to Make Payments to Secondary Recipient


A contribution by a private foundation to a recipient organization, which the recipient uses to make payments to a secondary recipient, is not a contribution by the private foundation to the secondary recipient if the foundation--

  • Does not earmark the use of the contribution for any named secondary recipient and
  • Does not keep the power to control the selection of the secondary recipient by the organization to which the foundation has contributed.

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