IRS Issues PLR Determining Unusual Grant Exclusion for Public Support, Preserving Charity Status

June 8, 2026, 2:10 PM UTC

The IRS has issued a private letter ruling on I.R.C. §509 and Treas. Regs. §§1.170A and 1.509 determining that a substantial cash grant from Foundation to taxpayer qualifies as an unusual grant exclusion for public support testing purposes, allowing taxpayer to maintain its I.R.C. §509(a)(2) public charity status. [PLR 202623021]

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