Scientific conference travel grants approved

Plain-English summary

A private foundation proposed grants for graduate students and postdoctoral researchers to travel to scientific conferences and similar educational events concerning the study of intelligence. Grants would help pay registration, travel, and lodging costs, with amounts based on financial need, event costs, available resources, and the number of awards. A board-member selection committee would consider academic potential, research quality and relevance, and financial need, while excluding insiders and their families. The foundation would pay expenses directly or reimburse documented costs, require post-event reports, verify attendance when possible, investigate diverted funds, and keep supervision records. The IRS approved the procedures under section 4945(g)(3).

Ruling snapshot

• Question: Did the foundation's scientific conference travel grant procedures satisfy the advance-approval rules?
• Outcome: Approved. Grants made under the described procedures will not be taxable expenditures.
• Key authorities: IRC §§ 74(b), 117, 170(b)(1)(A)(ii), and 4945(g); Treas. Reg. § 53.4945-4(c)(1).

Full text (IRS public release)

Internal Revenue Service Department of the Treasury
P.O. Box 2508
Cincinnati, OH 45201

Number: 201947018
Release Date: 11/22/2019 Employer Identification Number:

Contact person - ID number:

Date: August 27, 2019
Contact telephone number:

LEGEND UIL: 4945.04-04

x dollars = Amount
y dollars = Amount
Z = Number

Dear

You asked for advance approval of your educational grant procedures under Internal
Revenue Code Section 4945(g)(3). This approval is required because you are a private
foundation that is exempt from federal income tax.

Our determination

We approved your procedures for awarding educational grants. Based on the information
you submitted, and assuming you will conduct your program as proposed, we determined
that your procedures for awarding educational grants meet the requirements of Code
Section 4945(g)(3). As a result, expenditures you make under these procedures won't be
taxable.

Description of your request

Your letter indicates that you will operate an educational grant program. The purpose of
the grant program is to provide support for graduate students and postdoctoral
researchers for travel to and attendance at scientific conferences and similar educational
events.

Attending and presenting at professional scientific conferences is critical for the
development of future scientists. It gives them an opportunity to present their own
research and gain experience in answering questions the research may raise. It also
allows them to interact, collaborate, and network with other scientists in their field, which
helps to humanize the scientific effort. Additionally, it helps them to raise their academic
profiles, hone skills required for success in their fields, and gain confidence in their own
abilities.

Despite the educational and professional benefits, support for graduate student and
postdoctoral travel to and attendance at scientific conferences has become scarce over

the past decade. The purpose of your grants is to help fill this gap by making grants to
graduate students and postdoctoral researchers to defray expenses incurred in attending
scientific conferences and similar educational events. Each grant will be applied toward
the recipients’ travel, lodging, and/or conference registration or similar fees.

You will publicize the program primarily through scientific journals and magazines. You
will also work with conference or event organizers to publicize the program through any
conference or event website or materials, if possible. Additionally, you may publicize the
program through direct mail, e-mail, and word-of-mouth communications to educational
institutions, as well as through announcements and promotion by your Directors and
Officers.

The amount of the grant will vary depending on factors such as the resources you have
reserved for this program, the demonstrated financial need of the applicant, the cost of
attending the particular conference or event, and the number of grants you intend to
award in a particular year. You anticipate that graduate students and postdoctoral
researchers will receive between x dollars and y dollars. You anticipate making up to Z
awards each year, depending on the quality and quantity of the applications, and the
scientific conferences taking place that year.

Because each grant will be specific to a particular conference or event, there is no
process in place for renewal of a grant. A grantee who wishes to obtain a grant for a
conference or event in a subsequent year will be required to submit a new application for
that specific conference or event.

To be eligible to apply for a grant, the applicants must be graduate students or
postdoctoral researchers who desire to attend, or qualify to present at, scientific
conferences or similar educational events relating to the scientific study of intelligence.
Applicants will need to submit the application for a grant, although no specific form has
been developed to date. Applicants also should submit academic records or professional
achievement.

All grants will be awarded on an objective and non-discriminatory basis. Your selection
committee will be made up of certain members of your board of directors. The selection
committee will consider objective criteria, such as, but not limited to, the applicant's
potential for academic or professional achievement, the relevance and quality of research
performed by the applicant, and the applicant’s demonstrated financial need.

No Directors, Officers or substantial contributors, or family members thereof, may receive
a grant from you. Also, in no event will a grant be made for the benefit of a particular
individual if any Director, Officer, or substantial contributor, or any family member of the
foregoing, stands in a position to derive private benefit, directly or indirectly, from such
grant.

Letter 4779 (10-2012)
Catalog Number 58222Y

You anticipate that you will either pay the conference registration fees and related travel
and lodging expenses directly on behalf of the selected individuals, or you will require
receipts for those expenses from grantees, then you will reimburse.

Following the conference or event, grantees will be required to furnish you with a report
describing the use of the grant funds and the grantee’s progress toward achieving the
purposes of the grant. When possible, you also intend to independently verify the
grantee’s attendance at the conference with the conference organizer.

You represent that you will complete the following: (1) arrange to receive and review
grantee reports annually and upon completion of the purpose for which the grant was
awarded, (2) investigate diversion of funds from their intended purposes, (3) take all
reasonable and appropriate steps to recover the diverted funds, ensure other grant funds
held by the grantee are used for their intended purposes, and withhold further payments
to grantees until you obtain grantees’ assurances that future diversions will not occur and
that grantees will take extraordinary precautions to prevent future diversions from
occurring.

You represent that you will maintain all records related to the following: (1) individual
grants including information to evaluate grantees, (2) grantees which are identified as a
disqualified person, (3) how the amount and purpose of each grant was established, and
(4) how you established supervision and investigation of the grants described above.

Basis for our determination

The law imposes certain excise taxes on the taxable expenditures of private foundations
(Code Section 4945). A taxable expenditure is any amount a private foundation pays as a
grant to an individual for travel, study, or other similar purposes. However, a grant that
meets all of the following requirements of Code Section 4945(g) is not a taxable
expenditure.

• The foundation awards the grant on an objective and nondiscriminatory basis.
• The IRS approves in advance the procedure for awarding the grant.
• The grant is:

• A scholarship or fellowship subject to Section 117(a) and is to be used for
  study at an educational organization described in Section 170(b)(1)(A)(ii); or

• A prize or award subject to the provisions of Section 74(b), if the recipient of
  the prize or award is selected from the general public; or

• To achieve a specific objective; produce a report or similar product; or
  improve or enhance a literary, artistic, musical, scientific, teaching, or other
  similar skill or talent of the recipient.

To receive approval of its educational grant procedures, Treasury Regulations Section
53.4945-4(c)(1) requires that a private foundation show:

• The grant procedure includes an objective and nondiscriminatory selection
process.

Letter 4779 (10-2012)
Catalog Number 58222Y

• The grant procedure results in the recipients performing the activities the grants
were intended to finance.

• The foundation plans to obtain reports to determine whether the recipients have
performed the activities that the grants were intended to finance.

Other conditions that apply to this determination
• This determination covers only the grant program described above. This approval
will apply to succeeding grant programs only if their standards and procedures
don't differ significantly from those described in your original request.

• This determination applies only to you. It may not be cited as precedent.

• You cannot rely on the conclusions in this letter if the facts you provided have
changed substantially. You must report any significant changes in your program to
the Cincinnati Office of Exempt Organizations at:

Internal Revenue Service

Exempt Organizations Determinations
P.O. Box 2508

Cincinnati, OH 45201

• You cannot make grants to your creators, officers, directors, trustees, foundation
managers, or members of selection committees or their relatives.

• All funds distributed to individuals must be made on a charitable basis and must
further the purposes of your organization. You cannot award grants for a purpose
that is inconsistent with Code Section 170(c)(2)(B).

• You should keep adequate records and case histories so that you can substantiate
your grant distributions with the IRS if necessary.

We've sent a copy of this letter to your representative as indicated in your power of
attorney.

Please keep a copy of this letter in your records.
If you have any questions, please contact the person listed at the top of this letter.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Letter 4779 (10-2012)
Catalog Number 58222Y