If a private foundation makes a grant to a governmental agency, and the grant is earmarked for use by an individual for travel, study, or other similar purposes, the grant is not a taxable expenditure by the private foundation if the governmental agency satisfies the Service in advance that its grant-making program:

  1. Furthers exempt purposes under section 501(c)(3),
  2. Requires the individual grantee to submit annual progress reports, and
  3. Requires the organization to investigate jeopardized grants.

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