The formulas
- Net value = FMV of noncharitable-use assets - acquisition indebtedness - 1.5% cash deemed held for charitable activities
- Minimum investment return = 5% x net value
- Distributable amount = minimum investment return - section 4940 tax - income tax + recoveries
How it works
Section 4942(e) sets a private foundation's minimum investment return at 5 percent of the fair market value of assets not used directly in its exempt purpose, less acquisition indebtedness. Regulations section 53.4942(a)-2 deems the reasonable cash balances held for charitable activities to be 1.5 percent of that value unless the IRS allows a larger amount, which Form 990-PF Part IX line 4 deducts.
The distributable amount in Part X is the minimum investment return reduced by the section 4940 tax (1.39 percent of net investment income) and income tax, plus recoveries of earlier qualifying distributions. The foundation must make qualifying distributions of that amount by the end of the next tax year or face the 30 percent tax on undistributed income. Private operating foundations and short tax years follow different rules not applied here.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Are program-related assets in the base?
No. Assets used or held for use directly in carrying out the exempt purpose are excluded from the 5 percent base.
How is the fair market value of securities measured?
Section 4942(e)(2)(A) determines the value of securities with readily available market quotations on a monthly basis.
Sources
- 26 U.S.C. 4942, Taxes on failure to distribute income (LII)
- 26 CFR 53.4942(a)-2, Computation of undistributed income, eCFR
- 26 U.S.C. 4940, Excise tax based on investment income (LII)
- Instructions for Form 990-PF (2025), Internal Revenue Service
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