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September 24, 2012
The Department of Treasury and the IRS issued proposed regulations applicable to private foundations seeking to make grants to foreign organizations using equivalency determinations. The guidance broadens the range of professionals on whose written advice a private foundation…
NGOsource improves the efficiency of international grantmaking and aims to achieve a significant increase in cross-border philanthropy by centralizing, streamlining, and standardizing the equivalency determination process for U.S. grantmakers. NGOsource is a project of TechSoup and was started with…
Private foundations wishing to make a cross-border grant must ensure that:
The grant is clearly for a charitable purpose, and
The grant counts as a qualifying distribution for the purpose of meeting the foundation’s annual distribution requirement.
The easiest way for a private…
In international grantmaking, private foundations often make grants to organizations (“Initial Grantees”) that, in turn, re-grant those funds to other non-public charity organizations or individuals (“Secondary Grantees”).
Legal issues arise when a private foundation makes a grant to an Initial…
The private foundation executive director was concerned. Members of her board were going to make grants to promote public housing and economic development but none of the groups involved were the typical 501(c)(3)s to which the foundation normally made grants. One possibility seemed to be making a…
Americans may disagree about various aspects of war, but there is broad support for helping the men and women who are fighting in wars and the families they have left behind. Dedicated assistance groups are working to provide aid to military personnel and their relatives. This article surveys the…
This page outlines the range of purposes that qualify an organization for tax exemption under section 501(c)(3) of the Internal Revenue Code. It explains how the IRS and courts interpret key terms — especially "charitable" — and how those interpretations shape eligibility.
Permissible Exempt…
Developed for the Council on Foundations by Christopher J. Armstrong, Partner at Holland & Knight
Congress’s power to conduct inquiries, including information requests, the issuance of subpoenas, and public hearings has long been recognized by the courts as part of Congress’s power to…
After listening, research, and consultation with the field, the Council on Foundations is expanding legal support to help community foundations prepare for—and respond to—threats that could shape the future of the sector.
The resources presented on this page provide additional analysis,…
Last updated on July 1, 2025.
With many of the provisions in the Tax Cuts and Jobs Act (TCJA) (P.L. 115-97) expiring at the end of 2025, the 119th Congress is crafting tax legislation through the reconciliation process that will extend the TCJA and included the Republican majorities’ priorities…