The IRS made the following rulings with respect to donations made by a private foundation to match those made by employees of a corporation that is the foundation’s sole contributor:

  1. The donations that Foundation makes pursuant to its matching donation programs will not constitute self-dealing under section 4941.
  2. The donations that Foundation makes pursuant to its matching donation programs will be qualified distributions for Foundation under section 4942(g).
  3. The donations that Foundation makes pursuant to its matching donation programs will not constitute taxable expenditures under section 4945(d).

See PLR 201725008 by clicking here.

Note:  See also PLR 201725009, which reaches a similar conclusion.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.