In PLR 201001020, the IRS ruled that awards made through a private foundation's scholarship program qualify as awards made under an employer-related grant-making program under Internal Revenue Code section 4945(g)(1) and as such are not subject to an excise tax for taxible expenditures. Furthermore, the awards will be excludable from the gross income of the recipients. The foundation's scholarship program met the requirements for an employer-related program as set forth in Rev. Proc. 76-47 and followed the eligibility standards under Rev. Proc. 85-51.
See also PLR 201001021.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal
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