An amount set aside for a specific project may be treated as a qualifying distribution in the year set aside (but not in the year actually paid) if at the time of the set-aside the foundation establishes to the satisfaction of the Service that:

  1. The amount will actually be paid for the specific project within 60 months from the date of the first set-aside, and
  2. The set-aside satisfies the suitability test, that is, that the project is one that can be better accomplished by a set-aside than by immediate payment, or the foundation satisfies the cash distribution test.

Additional information

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