# Domestic Private Foundations and Related Excise

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Domestic Private Foundations and Related Excise
Taxes, Tax Year 2009
by Cynthia Belmonte
omestic private foundations filed 92,624 Forms
990-PF for Tax Year 2009, an increase of 2.0 percent over Tax Year 2008. These organizations held
$588.5 billion in total assets for Tax Year 2009, an increase in real terms of 10.5 percent over the previous
year.1 Despite the double-digit increase, total assets were
still significantly less than the $674.0 billion reported for
Tax Year 2007, before the recession fully took hold of
the domestic economy. Figure A includes selected financial data for Tax Years 2007 through 2009 for domestic
private foundations. For most asset types, amounts increased between Tax Years 2008 and 2009. However, for
the most liquid asset types, cash and savings and temporary cash investments, values decreased 7.9 percent and
6.3 percent, respectively.
Investment assets, which provide the basis for foundation giving, accounted for almost 92 percent of the
total asset value reported by private foundations for Tax
Year 2009. The total amount of investment assets held by
private foundations increased 11.3 percent, from $485.1
billion to $539.8 billion, between Tax Years 2008 and
2009. Of all investment types, corporate stock increased
the most in dollar terms, from $219.2 billion to $234.4
billion, during that period. In percentage terms, corporate bonds gained the most, 20.6 percent, from $38.0 billion to $45.8 billion, for the same time frame.
Despite decreases in contributions, gifts, and grants
received; dividends and interest from securities; and
interest on savings, total revenue increased 3.8 percent
between Tax Year 2008 and Tax Year 2009. This was a
significant improvement over the 54.6-percent decrease
in total revenue reported for the preceding time frame.
Private foundations reported $5.6 billion of net losses
from sales of assets, less than the $10.0 billion in losses
for Tax Year 2008. Though down 4.4 percent compared
to the previous year, contributions, gifts, and grants received remained the largest source of revenue, totaling
$42.4 billion in Tax Year 2009.
Total expenses incurred by private foundations decreased 8.0 percent between Tax Year 2008 and Tax Year

D

Cynthia Belmonte is an economist with the Special Studies
Special Projects Section. This article was prepared under
the direction of Melissa Ludlum, Chief.

114

2009. Disbursements for charitable purposes, which
include contributions, gifts, and grants paid as well as
private foundations’ operating and administrative expenses, decreased 4.4 percent. Private foundations distributed $40.9 billion in contributions, gifts, and grants
to the charitable sector, a 5.6-percent decrease from Tax
Year 2008.

The Statistics of Income Study
The Statistics of Income (SOI) Division conducts an
annual study of private foundations based on the information returns filed with the Internal Revenue Service
(IRS). The statistics presented in this article are based on
a sample of Forms 990-PF, Return of Private Foundation
(or Section 4947(a)(1) Charitable Trust Treated as a
Private Foundation), filed by domestic private foundations—private foundations organized in the United
States—selected to represent the entire filing population for Tax Year 2009. Additional statistics on reported
excise taxes on the activities described in Internal
Revenue Code (IRC) sections 4941–4945 are from Forms
4720, Return of Certain Excise Taxes on Charities and
Other Persons Under Chapters 41 and 42 of the Internal
Revenue Code, filed by domestic private foundations. Tax
Year 2009 includes all accounting periods beginning in
Calendar Year 2009 and thus ending between December
31, 2009, and November 30, 2010. Consequently, the
returns reflect fi nancial activity that occurred in either
Calendar Year 2009 or 2010 or some portion of both (see
the Data Sources and Limitations section for further
information).

Tax Definitions and Organizational Structure
Public charities and private foundations that are created
and operated for religious, charitable, scientific, educational, and certain other designated purposes can qualify
for exemption from Federal income tax under IRC section 501(c)(3). Most tax-exempt organizations are hospitals, schools, churches, and organizations that receive
broad support from the general public. These types of
tax-exempt organizations, commonly known as “public
charities,” file Form 990, Return of Organization Exempt
from Income Tax, or Form 990-EZ, the short version of
this information return.2

1 Dollar values were adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the U.S. Department of Commerce, Bureau
of Economic Analysis. Inflation-adjusted money amounts were calculated in 2009 constant dollars and are referred to in this article as “constant dollars” or “real dollars.”
2 For additional discussion of organizations other than private foundations that are tax exempt under IRC section 501(c)(3), see Arnsberger, Paul, “Nonprofit Charitable
Organizations, 2009,” Statistics of Income Bulletin, Fall 2012, Volume 32, Number 2.

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure A
Domestic Private Foundations: Selected Financial Items and Percentage Changes, in Constant Dollars,
Tax Years 2007–2009
[All figures are estimates based on samples—money amounts are in millions of dollars]

Tax year

Percentage change

Item
2007

2008

2009

Tax Years
2007–2008

(1)

(2)

(3)

(4)

Tax Years
2008–2009
(5)

Number of returns

84,613

90,850

92,624

7.4

2.0

Total assets (fair market value)

673,972

532,851

588,535

-20.9

10.5

Cash (non-interest bearing accounts)
Investment assets, total

7,684

8,307

7,654

8.1

-7.9

628,798

485,067

539,849

-22.9

11.3

Savings and temporary cash investments

49,134

48,917

45,838

-0.4

-6.3

Investments in securities, total

413,531

291,059

324,673

-29.6

11.5

Government obligations

37,317

33,795

35,415

-9.4

4.8

Corporate stock

333,966

219,242

243,423

-34.4

11.0

Corporate bonds

42,248

38,021

45,835

-10.0

20.6

Other investments [1]

166,133

145,091

169,338

-12.7

16.7

Total revenue

110,845

50,270

52,179

-54.6

3.8

Contributions, gifts, and grants received

50,008

44,312

42,380

-11.4

-4.4

Net gain (less loss) from sales of assets

39,981

-10,009

-5,556

-125.0

44.5

41,158

9,150

7,020

-77.8

-23.3

1,177

19,159

12,576

1,527.8

34.4

13,583

11,321

9,030

-16.7

-20.2
-34.8

Gain
Loss
Dividends and interest from securities
Interest on savings

2,901

2,119

1,381

-27.0

60,690

61,045

56,185

0.6

-8.0

Disbursements for charitable purposes

50,799

50,288

48,062

-1.0

-4.4

Contributions, gifts, and grants paid

43,983

43,336

40,914

-1.5

-5.6

Operating expenses

4,732

6,952

7,148

46.9

2.8

50,155

-10,776

-4,006

-121.5

62.8

Total expenses

Excess of revenue over expenses

[1] Sum of "Investments in land, buildings, and equipment (less accumulated depreciation)," "Investments in mortgage loans," and miscellaneous items such as advances; certificates of
investment; and investments in art, coins, gold, and gems.
NOTE: Money amounts are in 2009 "constant dollars" and have been adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the
U.S. Department of Commerce, Bureau of Economic Analysis. Detail may not add to totals because of rounding.

In contrast to a public charity, a private foundation relies on a narrow sphere of support, typically
through funding from a small number of private donors.
Additionally, control of a private foundation is generally
limited to an individual, family, or corporation. Some
private foundations operate their own charitable programs, but the vast majority of private foundations support charitable activities through grants to individuals or
other tax-exempt organizations.
Private foundations are subject to a variety of IRS
regulations regarding their activities. Private foundations
use the annual information return Form 990-PF to report
detailed financial information as well as compliance with
IRS regulations. Certain nonexempt charitable trusts that
are treated as private foundations for tax purposes are
also required to file this return. Though exempt from
3

income tax, private foundations are required to pay annually an excise tax on their net investment incomes.
Additionally, private foundations and foundation managers are required to file Form 4720 to report excise taxes
on certain prohibited activities.

Composition of Filers
Depending upon the type of charitable support that a
private foundation provides, it may be classified as either
“nonoperating” or “operating.” 3 A nonoperating foundation supports charitable programs indirectly, providing
grants to other charitable organizations, rather than
operating programs of its own. In contrast, an operating foundation generally spends its income or assets on
direct, active involvement in a tax-exempt, charitable activity, such as operating a library or museum, providing

An organization’s status as a nonoperating or operating foundation was indicated on Form 990-PF, Part VII-A, line 9.

115

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

housing or healthcare, or conducting scientific research.
In order to qualify as operating, a foundation must meet
both an “income test” and one of three other tests: an
“assets test,” an “endowment test,” or a “support test.” 4
Figure B presents financial data for Tax Year 2009,
by asset-size class, for all foundations, and for nonoperating and operating foundations, separately.5 Although
more than two-thirds of all returns filed by private foundations for Tax Year 2009 were filed by foundations with
less than $1 million of total assets, combined, these organizations held less than 3 percent of the total assets. The

largest foundations, those holding total assets valued at
$100 million or more, represented less than 1 percent of
all returns filed for Tax Year 2009; however, these organizations held 58.6 percent of total assets.
The smallest foundations earned 8.1 percent of
total revenue and accounted for 10.0 percent of the total
amount disbursed for charitable purposes. The largest
foundations accounted for more than half of total revenue
and more than 45 percent of disbursements for charitable
purposes and contributions, gifts, and grants paid by domestic private foundations for Tax Year 2009.6

Figure B
Domestic Private Foundations: Selected Financial Items, by Operating Status and Size of End-of-Year
Fair Market Value of Total Assets, Tax Year 2009
[Money amounts are in millions of dollars]

Total assets
(fair market value)

Returns

Disbursements for
charitable purposes

Total revenue

Contributions, gifts,
and grants paid

Operating status and asset size [1]
Number

All foundations

Percentage
Percentage
Amount
Amount
of total
of total

(1)

(2)

(3)

(4)

Percentage
Amount
of total

(5)

(6)

Percentage
Amount
of total

(7)

(8)

(9)

Percentage
of total
(10)

92,624

100.0

588,535

100.0

52,179

100.0

48,062

100.0

40,914

Less than $1,000,000

61,883

66.8

15,558

2.6

4,224

8.1

4,784

10.0

3,523

8.6

$1,000,000 less than $10,000,000

24,520

26.5

77,041

13.1

6,841

13.1

7,186

15.0

6,233

15.2

$10,000,000 less than $50,000,000

4,776

5.2

99,584

16.9

10,181

19.5

9,860

20.5

8,470

20.7

$50,000,000 less than $100,000,000

740

0.8

51,200

8.7

3,600

6.9

4,229

8.8

3,682

9.0

$100,000,000 or more

705

0.8

345,152

58.6

27,334

52.4

22,003

45.8

19,005

46.5
93.9

Nonoperating foundations

100.0

84,660

91.4

539,712

91.7

44,571

85.4

42,153

87.7

38,422

Less than $1,000,000

55,923

60.4

14,714

2.5

2,959

5.7

3,713

7.7

3,464

8.5

$1,000,000 less than $10,000,000

23,021

24.9

72,272

12.3

5,626

10.8

6,374

13.3

5,962

14.6

$10,000,000 less than $50,000,000

4,395

4.7

91,598

15.6

7,252

13.9

7,530

15.7

6,892

16.8

$50,000,000 less than $100,000,000

682

0.7

47,301

8.0

2,865

5.5

3,660

7.6

3,270

8.0

$100,000,000 or more

639

0.7

313,828

53.3

25,870

49.6

20,876

43.4

18,833

46.0

Operating foundations

7,964

8.6

48,823

8.3

7,608

14.6

5,909

12.3

2,491

6.1

Less than $1,000,000

5,960

6.4

844

0.1

1,265

2.4

1,071

2.2

58

0.1

$1,000,000 less than $10,000,000

1,499

1.6

4,769

0.8

1,215

2.3

812

1.7

271

0.7

$10,000,000 less than $50,000,000

381

0.4

7,986

1.4

2,928

5.6

2,330

4.8

1,578

3.9

$50,000,000 less than $100,000,000

58

0.1

3,899

0.7

735

1.4

570

1.2

412

1.0

$100,000,000 or more

66

0.1

31,324

5.3

1,464

2.8

1,127

2.3

173

0.4

[1] Foundations were assigned to asset-size classes based on the reported current dollar end-of-year fair market value of total assets.
NOTE: Detail may not add to totals because of rounding.

116

4 A foundation could qualify as operating under the income requirement if it spent at least 85 percent of the lesser of its “minimum investment return” or “adjusted net income”
on the direct, active conduct of tax-exempt, charitable activities. Adjusted net income represented the amount of income from charitable functions, investment activities,
set-asides, unrelated business activities, and short-term capital gains that exceeded the cost incurred in earning the income and was calculated in Part I, column (c), of Form
990-PF for operating foundations. To meet the assets test, a foundation had to use 65 percent or more of its assets directly for the active conduct of charitable activities. To
meet the endowment test, a foundation regularly had to make distributions for the active conduct of charitable activities in an amount not less than two-thirds of its “minimum
investment return.” To meet the support test, a foundation regularly had to receive substantially all of its support (other than from gross investment income) from the public
or from five or more qualifying exempt organizations, and (a) no more than 25 percent of its support (other than from gross investment income) from any one such qualifying
exempt organization; and (b) no more than 50 percent of its support from gross investment income. See “Operating Foundations” in the Explanation of Selected Terms section
of this article for additional information.
5 Foundations were assigned to asset-size classes based on the reported end-of-year fair market value of total assets.
6 Disbursements for charitable purposes include contributions, gifts, and grants paid, as well as expenses related to the foundation’s charitable purpose, such as employee
salaries and wages, occupancy, and printing and publications.

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Nonoperating foundations are by far the most
common type of Form 990-PF filer and conduct the majority of financial activity that is attributable to private
foundations. For Tax Year 2009, nonoperating foundations accounted for 91.4 percent of Forms 990-PF
filed by domestic private foundations, and they held a
similar proportion of the aggregate value of total assets.
Nonoperating foundations also earned the majority of
total revenue, and, because they primarily supported
charitable activities via indirect distributions, accounted
for nearly all of the contributions, gifts, and grants
reported.

The Private Foundation Rules
Since private foundations are typically supported and
controlled by an individual, family, or corporation, they
are not directly accountable to the public. Consequently,
private foundations are subject to greater Federal regulation than other tax-exempt organizations. For example,
private foundations are required annually to distribute
their minimum investment return, statutorily defi ned
as 5 percent of the net value of their investment assets,
after certain adjustments. The Tax Reform Act of 1969
(TRA69) established taxes specific to private foundations and was the basis for IRC sections 4940–4945.
IRC section 4940 includes an excise tax on “net investment income,” which consists of income received only
from investments that are unrelated to a foundation’s
charitable purpose. This tax, which is reported annually on Form 990-PF, applies to all nonoperating foundations and to most operating foundations that earn net
investment income.
IRC sections 4941–4945 outline taxes imposed on
foundations that engage in activities that are considered
to be contrary to the public interest. Figure C provides
detailed descriptions of taxable activities under IRC
sections 4941–4945, as well as the tax rates associated
with each section. Private foundations report taxes on
the activities described in IRC sections 4941–4945 on
Form 4720. Taxes reported on Form 4720 are initial
taxes; these fi rst-tier taxes are assessed automatically
when a prohibited activity occurs. If a foundation, after
paying their 4720 excise tax, fails to provide corrective
action, the foundation may be subject to an additional
second-tier tax.7
Excise taxes under IRC sections 4940 through 4945 can
be divided into two primary categories—organizational

7
8

and individual. The most common organizational excise
tax is levied on net investment income under IRC section
4940. Additionally, foundations that engage in prohibited activities are subject to organizational excise taxes
on undistributed income, investments that jeopardize
charitable purpose, excess business holdings, and taxable expenditures. Individual excise taxes include many
of the organizational taxes, but are imposed on foundation managers who knowingly engage in the prohibited
activity. Self-dealing tax is the only excise tax defined
under IRC sections 4940 through 4945 that does not have
an organizational component. A self-dealer, defined as
a disqualified person benefiting from a prohibited transaction with a foundation, is liable for self-dealing tax.
Additionally, foundation managers who knowingly participate in acts of self-dealing are also subject to excise
taxes.
Figure D shows excise tax data for Tax Years 2008
and 2009, classified by organizational or individual
excise taxes. The number of organizations and individuals that incurred excise taxes under IRC sections 4940–
4945 decreased, as did the amount of total taxes reported
between Tax Years 2008 and 2009. This was attributable
to the significant decrease in reported taxes on net investment income, which fell by 24.5 percent. The remainder
of the article examines IRC section 4940–4945 excise
taxes reported for Tax Year 2009 in detail.

Investment Assets and the Section 4940 Tax
on Investment Income
Assets that are held for investment purposes only, such
as securities, investments in art, coins or other collectables, and real estate, are classified as noncharitable-use
assets. For nonoperating foundations, noncharitable-use
assets typically represent the majority of total assets.
Most types of noncharitable-use assets, including cash
and securities, are valued based on their average monthly
fair market values throughout the tax year, while total
assets are valued at year’s end.8 Figure E presents aggregate total assets and noncharitable-use assets held by
domestic nonoperating private foundations, as well as
net investment income, for Tax Years 2008 and 2009.
Despite an overall real increase of 12.0 percent in nonoperating foundations’ aggregate total assets between Tax
Years 2008 and 2009, the net value of noncharitable-use
assets held for investment purposes decreased 10.7 percent over the same period.

Additional levels of tax are not reported on the Form 4720; rather, they are handled independently between the IRS and the foundation and/or foundation manager.
Other types of noncharitable-use assets are valued annually, although not necessarily at year’s end.

117

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure C
Excise Taxes on Prohibited Activities Described Under Internal Revenue Code Sections 4941-4945
Code
section
4941

Name of tax
Self-Dealing

Description
(1) Selling, exchanging, or leasing of property to a disqualified person.
(2) Borrowing money from, lending money to, or otherwise extending credit
to a disqualified person.

Tax rate [1], [2]
10-percent initial tax per act per year on SelfDealer.
5 percent per year and limited to $20,000
per act on Foundation Managers.

(3) Furnishing goods, services, or facilities to a disqualified person.
(4) Paying compensation to, or paying or reimbursing the expenses of,
a disqualified person.
(5) Transferring any income or assets to a disqualified person.
(6) Paying money or property to a Government official.
4942

Undistributed Income

Failing to distribute the minimum required amount.

30-percent initial tax on current and previous
years' undistributed amount.

4943

Excess Business
Holdings

Holding more than 20-percent interest in an unrelated business enterprise.

10-percent initial tax on excess amount and
200 percent if not disposed of within tax
period.

4944

Investments that
Failing to exercise ordinary business care to provide for the long- and shortJeopardize Charitable term financial needs of the foundation.
Purpose

10-percent initial tax of amount invested per
year on Foundation.
10-percent initial tax of amount invested per
year on Foundation Manager and limited to
$10,000 for any one investment.

4945

Taxable Expenditures (1) Carrying on propaganda or otherwise influence any legislation through:

20-percent initial tax of expenditure on
Foundation.

(a) Attempting to influence public opinion or any segment of it, and
(b) Communicating with any member or employee of a legislative body,
or with any other Government official or employee who may take part
in formulating legislation.

5-percent initial tax up to $10,000 on
Foundation Managers.

(2) Influencing the outcome of any specific public election, or to conduct,
directly or indirectly, any voter registration drive.
(3) Providing a grant to an individual for travel, study, or other purposes.
(4) Providing a grant to an organization not described in section
509(a)(1), (2), or (3) or that is not an exempt operating foundation.
(5) Acting with any other than religious, charitable, scientific, literary,
educational, or public purposes, or the prevention of cruelty to children
or animals.
[1] Taxes on Foundation Managers require that the manager knew the action was a taxable act and the manager participated willingly.
[2] Tax rates and amounts reflect legislation included in the Pension Protection Act of 2006 (PPA), which doubled the penalty excise taxes effective for taxable years beginning after
August 17, 2006.

118

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure D
IRC Sections 4940-4945 Excise Taxes Reported by Domestic Private Foundations, and Percentage
Changes, in Constant Dollars, Tax Years 2008 and 2009 [1]
[Money amounts are in thousands of dollars]

Number of returns
Internal Revenue Code section and item [2]

Taxes on organizations [3]
Section 4940 tax on net investment income
Section 4942 tax on undistributed income
Section 4943 tax on excess business holdings
Section 4945 tax on taxable expenditures
Taxes on individuals [4]
Section 4941 tax on self-dealing
Section 4945 tax on taxable expenditures

Amount involved in act

2008

2009

Percentage
change

(1)

(2)

(3)

69,313
1,350
**
** 73

66,743
1,285
5
98

134
12

107
13

2008
(4)

Tax amount

2009

Percentage
change

2008

2009

Percentage
change

(5)

(6)

(7)

(8)

(9)

-3.7 23,371,332 17,254,016
-4.8
25,189
20,833
N/A
**
13,714
N/A
** 2,357
3,183

-26.2 292,537 220,966
-17.3
7,557
6,250
N/A
**
1,371
N/A
** 405
637

-24.5
-17.3
N/A
N/A

-20.1
8.3

38.9
-75.6

34.4
-73.6

10,745
294

14,921
72

1,270
15

1,707
4

** Data combined to prevent disclosure of specific taxpayer data.
N/A—Not applicable.
[1] Excise tax under IRC section 4940 is reported on the Form 990-PF, while the taxes under IRC sections 4941-4945 are reported on the Form 4720. The tax year data include Forms
990-PF and Forms 4720 filed and processed during the two calendar years immediately following the tax year.
[2] There were no Form 4720 returns filed by foundations reporting section 4944 taxes on jeopardizing investments for the time period covered.
[3] Organization taxes are reported by private foundations.
[4] Individual taxes are reported by foundations managers, office directors, trustees, and other individuals.
NOTE: Money amounts are in 2009 "constant dollars" and have been adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the
U.S. Department of Commerce, Bureau of Economic Analysis. Detail may not add to totals because of rounding.

Figure E
Domestic Nonoperating Private Foundations: Total Assets, Noncharitable-Use Assets, and Net
Investment Income, by Size of End-of-Year Fair Market Value of Total Assets, in Constant Dollars,
Tax Years 2008–2009
[All figures are estimates based on samples–money amounts are in millions of dollars]

Number of returns
Asset size [1]

Total assets (fair market value)

2008

2009

Percentage
change

2008

2009

Percentage
change

(1)

(2)

(3)

(4)

(5)

(6)

481,924
14,782
65,896
82,599
44,763
273,884

539,712
14,714
72,272
91,598
47,301
313,828

All nonoperating foundations
Less than $1,000,000
$1,000,000 less than $10,000,000
$10,000,000 less than $50,000,000
$50,000,000 less than $100,000,000
$100,000,000 or more

83,024
56,638
21,196
3,975
649
565

84,660
55,923
23,021
4,395
682
639

2.0
-1.3
8.6
10.6
5.1
13.1

Noncharitable-use assets [2]
Asset size [1]

All nonoperating foundations
Less than $1,000,000
$1,000,000 less than $10,000,000
$10,000,000 less than $50,000,000
$50,000,000 less than $100,000,000
$100,000,000 or more

12.0
-0.5
9.7
10.9
5.7
14.6

Net investment income

2008

2009

Percentage
change

2008

2009

Percentage
change

(7)

(8)

(9)

(10)

(11)

(12)

523,014
17,029
72,791
89,559
47,928
295,707

467,188
13,473
64,904
81,378
41,874
265,559

-10.7
-20.9
-10.8
-9.1
-12.6
-10.2

22,091
736
3,386
4,151
1,952
11,866

16,612
550
2,390
3,063
1,575
9,034

-24.8
-25.3
-29.4
-26.2
-19.3
-23.9

[1] Foundations were assigned to asset-size classes based on the constant dollar end-of-year fair market value of total assets for each tax year.
[2] While not common, the fair market value of noncharitable-use assets can exceed the ending fair market value of total assets because of the different methods used for calculating
the two values. Most types of noncharitable-use assets, including cash and securities, are valued based on their average monthly fair market values throughout the tax year, while total
assets are valued at year end.
NOTE: Money amounts are in 2009 "constant dollars" and have been adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the
U.S. Department of Commerce, Bureau of Economic Analysis. Detail may not add to totals because of rounding.

119

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Income received from investment assets decreased
significantly between Tax Years 2008 and 2009. Realized
net investment income reported by private foundations
included net income from capital gains, along with interest, dividends, rents, and royalties, after deductions for
expenses incurred in producing the investment income.
Domestic nonoperating private foundations reported
$16.6 billion in net investment income, a 24.8-percent
decrease from the $22.1 billion in 2008.
The “net investment income yield” and “real rates
of total return on assets” can provide additional insight
into both the realized income from, and the overall performance of, investment assets. Figure F shows these
measures for domestic nonoperating foundations for Tax
Years 2008 and 2009. Both the mean and the median,
which minimizes the influences of large outliers in the
data and may therefore better represent a typical foundation than the mean value, are shown. In order to compare
investment performance by foundation size over a given
tax year, foundations were classified based on their fair
market value of assets at the beginning of the year.
The net investment income yield, a measure of the
realized investment income that a foundation earns on its

investment assets, was calculated by dividing net investment income by the value of noncharitable-use assets.
The median net investment income yield realized by
domestic nonoperating private foundations fell slightly,
from 2.4 percent for Tax Year 2008 to 1.9 percent for
Tax Year 2009. Median net investment income yields
varied little among foundations in the different asset-size
classes. Median net investment income yields generally
increased with the size of the foundation, with the smallest foundations reporting the lowest median net investment income yield, at 1.5 percent. Foundations with $10
million to $100 million in total assets had the highest
median net investment income yield (2.4 percent), while
the largest foundations realized slightly lower median net
investment income yields of 2.1 percent.
The real rate-of-total-return formula, which measures the total, inflation-adjusted capital appreciation
of a foundation’s assets, equals the change in the value
of the entire asset base (adjusted for contributions received, grants paid, and certain expenses) divided by the
value of the base. Because the real rate of total return on
assets measures the realized income from investments
and other assets, as well as the unrealized appreciation or

Figure F
Domestic Nonoperating Private Foundation Net Investment Income Yields and Real Rates
of Total Return on Assets, by Size of Beginning-of-Year Fair Market Value of Total Assets,
Tax Years 2008–2009 [1]
Net investment income
yields (percentages)

Real rates of total return
on assets (percentages)

Tax year, asset size [2]
Median

Mean

(1)
Tax Year 2008, Nonoperating foundations
Less than $1,000,000

Median

Mean

(3)

(4)

(5)

Standard
deviation
(6)

2.4

7.4

236.8

-15.7

-9.7

272.6

2.0

7.5

306.9

-8.7

-3.9

855.0

$1,000,000 less than $10,000,000

2.7

7.8

464.8

-21.9

-19.5

63.3

$10,000,000 less than $50,000,000

2.6

4.6

11.6

-21.6

-17.9

43.2

$50,000,000 less than $100,000,000

2.5

7.5

93.2

-22.2

-19.0

15.9

$100,000,000 or more

2.5

4.0

9.8

-24.6

-21.4

14.8

1.9

6.1

129.5

11.1

33.9

1,424.6
4,286.1

Tax Year 2009, Nonoperating foundations

120

(2)

Standard
deviation

Less than $1,000,000

1.5

6.5

273.9

8.5

43.4

$1,000,000 less than $10,000,000

2.3

5.8

189.8

13.7

14.8

85.6

$10,000,000 less than $50,000,000

2.4

4.5

32.9

13.4

15.0

37.0

$50,000,000 less than $100,000,000

2.4

3.8

6.1

13.2

14.2

17.0

$100,000,000 or more

2.1

3.2

5.7

14.1

14.7

14.9

[1] Only data from returns that were included in the sample for 2 consecutive tax years were used in the calculations. For example, the Tax Year 2009 net investment income yield and
rate of return on total assets were calculated only for organizations that filed sampled returns for each of Tax Years 2008 and 2009. Thus, approximately 76 percent of returns for
nonoperating foundations included in the Tax Year 2009 sample were eligible for this analysis. Eligible returns represented 91 percent of the Tax Year 2008 sample. Because some
organizations may have exited the sample in consecutive years due to decreases in their fair market values of total assets, these results may reflect some bias toward organizations
with positive investment performance.
[2] Foundations were assigned to asset-size classes based on the constant dollar beginning-of-year fair market value of total assets for each tax year.
NOTE: Money amounts are in 2009 "constant dollars" and have been adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the
U.S. Department of Commerce, Bureau of Economic Analysis.

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

depreciation in the fair market value of assets, it provides
a more comprehensive measure of total investment performance than the net investment income yield. Overall,
median rates of total return realized by nonoperating
foundations increased sharply between Tax Years 2008
and 2009, from -15.7 percent to 11.1 percent. In comparison, the market rate of return, as measured by Standard
and Poor’s (S&P) 500 index, fell 38.5 percent in 2008 and
rose 23.5 percent in 2009.9
For Tax Year 2009, the median real rate of total return
for nonoperating foundations in each asset-size class was
positive. The median rates of total return generally increased with the size of the foundation, with the smallest foundations reporting the lowest median rate of total
return, at 8.5 percent, and the largest foundations reporting the highest median rate of total return, at 14.1 percent.
Most private foundations are required to pay an
excise tax on net investment income under IRC section
4940.10 This excise tax is intended to cover expenses incurred by the IRS in the oversight of private foundation
activities and the enforcement of laws governing private foundations’ exempt status. Generally, the excise
tax rate for domestic private foundations equals 2 percent of net investment income. The continued decline in

private foundation net investment income resulted in a
decrease in the total amount of IRC section 4940 excise
taxes between Tax Years 2008 and 2009, as shown in
Figure G. For Tax Year 2008, in real terms, $22.9 billion
of the $23.4 billion in net investment income reported
by all domestic foundations was subject to the excise tax,
which totaled $293 million. Of the $17.6 billion in net
investment income reported by all domestic foundations
for Tax Year 2009, $17.3 billion was subject to the excise
tax, which totaled just $221 million.
Under IRC section 4940(e), domestic private foundations can qualify for a reduced net investment income
tax rate of 1 percent if they can show growth in the rate
of their charitable distributions. If total Tax Year 2009
qualifying distributions were larger than the total of averaged qualifying distributions made between 2004 and
2008 plus 1 percent of Tax Year 2009 net investment
income, a foundation was eligible for the reduced tax
rate for Tax Year 2009. Similar to the previous year, over
52 percent of the foundations reporting excise taxes on
net investment income qualified for the reduced 1-percent tax rate for Tax Year 2009. Generally, larger foundations were more likely to qualify for the reduced tax
rate than smaller foundations; for example, for Tax Year

Figure G
Domestic Private Foundations Reporting IRC Section 4940 Excise Tax on Investment Income, by Size
of End-of-Year Fair Market Value of Total Assets, in Constant Dollars, Tax Years 2008–2009
[Money amounts are in millions of dollars]

Tax year, asset size [1]

Tax Year 2008, all foundations [2]

Percentage of
foundations reporting:

Number
of returns

Percentage
of all
foundations

Net
investment
income

Qualifying
distributions

Section 4940
tax on net
investment
income

1-Percent
tax

2-Percent
tax

(1)

(2)

(3)

(4)

(5)

(6)

(7)

69,313

76.3

22,906

45,633

293

52.9

47.1

Less than $1,000,000

43,229

69.3

750

2,605

11

49.6

50.4

$1,000,000 less than $10,000,000

20,823

91.4

3,486

7,505

50

57.3

42.7

$10,000,000 less than $50,000,000

4,023

92.5

4,296

8,598

59

62.0

38.0

$50,000,000 less than $100,000,000

659

92.8

2,116

4,796

27

65.9

34.1

$100,000,000 or more

579

92.9

12,258

22,128

146

64.1

35.9

66,743

72.1

17,254

41,684

221

52.7

47.3

Less than $1,000,000

38,682

62.5

555

1,931

8

50.2

49.8

$1,000,000 less than $10,000,000

22,348

91.1

2,443

6,456

35

54.9

45.1

$10,000,000 less than $50,000,000

4,374

91.6

3,219

7,493

45

60.1

39.9

$50,000,000 less than $100,000,000

686

92.7

1,631

3,958

22

61.1

38.9

$100,000,000 or more

653

92.6

9,406

21,847

112

67.5

32.5

Tax Year 2009, all foundations [2]

[1] Foundations were assigned to asset-size classes based on the reported constant dollar end-of-year fair market value of total assets for each tax year.
[2] Domestic private foundations reporting IRC Section 4940 excise tax on investment income.
NOTE: Money amounts are in 2009 "constant dollars" and have been adjusted for inflation based on the 2005 chain-type price index for Gross Domestic Product, as published by the
U.S. Department of Commerce, Bureau of Economic Analysis. Detail may not add to totals because of rounding.

9

Historical prices for the S&P 500 Index were obtained from the Google Finance Web site at http://www.google.com/fi nance.

10 Some foundations were not required to pay the IRC section 4940 excise tax on net investment income. Certain foundations in IRC section 507(b)(1)(B) termination status,

as well as certain exempt operating foundations described in IRC section 4940(d)(2), were exempt from paying the excise tax.

121

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

2009, more than 60 percent of foundations with assets
of $10 million or more were eligible for the reduced rate,
compared to roughly half of foundations with less than
$1 million in assets. Despite the lower average tax rates,
foundations with assets of $10 million or more accounted
for 81 percent of total tax liability for Tax Year 2009.

the indebtedness incurred to acquire these assets and the
amount of cash held for charitable activities. The distributable amount is the minimum investment return minus
the excise tax on net investment income, plus or minus
other adjustments (see Net Adjustments to Distributable
Amount and Net Value of Noncharitable-use Assets in
the Explanation of Terms section of this article for additional details).
The current year’s distribution requirement may be
satisfied by qualifying distributions from the current year
as well as excess distributions carryovers from the previous 5 tax years. Qualifying distributions are those made
for charitable purposes. Although qualifying distributions consist primarily of contributions, gifts, and grants
disbursed throughout the year, they may also include operating and administrative expenses related to conducting charitable operations; program-related investments,
such as loans to other 501(c)(3) organizations; amounts
paid to acquire buildings, equipment, supplies, or other
assets for charitable-use; and “set-asides,” which are
amounts earmarked for future charitable distributions.
Qualifying distributions and their components,
along with distributable amounts, are shown for nonoperating foundations by asset-size class in Figure H.
Nonoperating foundations paid $43.3 billion in total

The Charitable Distribution Requirement and
the IRC Section 4942 Tax on Undistributed
Income
The overall value of assets held by a private foundation,
particularly those held for investment purposes, can play
a major role in the foundation’s ability to make distributions for charitable purposes. For nonoperating foundations, the annual charitable distribution requirement,
known as the “distributable amount,” is calculated based
on an annual valuation of assets. As a result, fluctuations
in asset values can directly affect the grantmaking practices of nonoperating foundations. IRC section 4942 outlines the annual distribution requirement and the excise
tax penalty assessed on nonoperating foundations that
fail to meet it. The distributable amount is derived from
a foundation’s minimum investment return, which equals
5 percent of the net value of noncharitable-use assets, calculated as the value of noncharitable-use assets, less both

Figure H
Domestic Nonoperating Private Foundations: Qualifying Distributions and Distributable Amount,
by Size of End-of-Year Fair Market Value of Total Assets, Tax Year 2009
[Money amounts are in millions of dollars]

Qualifying distributions

Total

Contributions,
gifts, and
grants paid

Operating
expenses

Programrelated
investments

Amounts paid
to acquire
assets

Set-asides

Distributable
amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

Asset size [1]

All nonoperating foundations

43,280

38,422

3,730

534

499

94

Less than $1,000,000

3,733

3,464

249

16

1

2

23,434
666

$1,000,000 less than $10,000,000

6,479

5,962

411

74

21

10

3,214

$10,000,000 less than $50,000,000

7,635

6,892

638

70

30

5

4,039

$50,000,000 less than $100,000,000

3,734

3,270

389

33

26

15

2,078

$100,000,000 or more

21,699

18,833

2,043

341

421

62

13,437

N/A

Percentage of total qualifying distributions

122

All nonoperating foundations

100.0

88.8

8.6

1.2

1.2

0.2

Less than $1,000,000

100.0

92.8

6.7

0.4

[2]

0.1

N/A

$1,000,000 less than $10,000,000

100.0

92.0

6.4

1.1

0.3

0.2

N/A

$10,000,000 less than $50,000,000

100.0

90.3

8.3

0.9

0.4

0.1

N/A

$50,000,000 less than $100,000,000

100.0

87.6

10.4

0.9

0.7

0.4

N/A

$100,000,000 or more

100.0

86.8

9.4

1.6

1.9

0.3

N/A

N/A—Not applicable.
[1] Foundations were assigned to asset-size classes based on the reported current dollar end-of-year fair market value of total assets.
[2] Less than 0.05 percent
NOTE: Detail may not add to totals because of rounding.

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

qualifying distributions for Tax Year 2009, of which
88.8 percent were in the form of contributions, gifts, and
grants paid. Another 8.6 percent of qualifying distributions consisted of operating and administrative expenses.
Program-related investments, amounts paid to acquire
assets, and set-asides accounted for the remaining 2.6
percent of qualifying distributions. As asset size increased, contributions, gifts, and grants paid made up a
smaller share of qualifying distributions.
Foundations’ qualifying distributions exceeded the
required distributable amount of $23.4 billion to varying degrees across each asset-size category. Generally,
as asset size increased, the extent to which foundations’
qualifying distributions exceeded the required distributable amount decreased. In aggregate, the smallest foundations, those with less than $1 million of total assets, reported total qualifying distributions that were more than
five times larger than their required distributable amount.
As a group, foundations with assets between $1 million
and $10 million disbursed twice their required distributable amount in qualifying distributions, while those with
assets of $10 million or more disbursed slightly less than
twice their required distributable amount.
The payout rate captures the relationship between
an organization’s qualifying distributions and its investment assets. Current-year distributions, combined with
carryovers, are adjusted to include certain taxes and
deductions and divided by the total value of noncharitable-use assets to arrive at a foundation’s payout rate.
This rate provides a measure of a foundation’s success in
meeting the annual required distributable amount. The
distribution of payout rates for domestic nonoperating
foundations, by selected percentiles, is illustrated in
Figure I.
The percentile distribution of payout rates followed
the same general trend in each of Tax Years 2008 and
2009. Payout rates for the vast majority of foundations
ranged between 2.5 percent and 7.5 percent. For foundations with $1 million or more of total assets, rates were
generally uniform, with differences of roughly 1 percent
among the various asset-size classes. However, for the
smallest foundations, those with less than $1 million of
total assets, the range of payout rates was more significant—between 0.03 percent for the fifth percentile and
28.9 percent for the seventy-fifth percentile.
Some 20 percent of all foundations had payout rates
at or below the 5-percent requirement. Within this group,
payout rates for the smallest foundations were smaller
and increased more dramatically compared to the rates of
larger foundations. Above the 5-percent payout requirement, rates for the smallest foundations were larger and

again climbed more sharply relative to larger foundations’
payout rates.
Median payout rates held fairly constant between
Tax Years 2008 and 2009; the median payout rate for all
foundations in each of these years was 6.2 percent. While
the median payout rate for foundations with $1 million
or more of total assets was between 5.7 and 5.9 percent
for Tax Year 2009, the smallest foundations had a median
payout rate of 6.8 percent.
Foundations must meet the distributable amount requirement for the current tax year by the end of the next
tax year or pay excise tax on the undistributed amount.
For example, a foundation must have disbursed the required amount for Tax Year 2008 before the end of Tax
Year 2009 in order to avoid paying the excise tax under
IRC section 4942. As foundations do not calculate their
required distributable amounts until the end of the tax
year, they may choose to take advantage of the 1-year,
tax-free “grace period” for making these distributions
and report all or part of their current-year required distributions as undistributed income. The majority of foundations with a minimum distribution requirement for Tax
Year 2009 met or exceeded their distribution requirement
by the end of the tax year. Some 34.0 percent reported
undistributed income for the year; these foundations
had until the end of Tax Year 2010 before these amounts
became taxable.
Private foundations report taxable amounts of undistributed income and compute related excise tax liability on Form 4720. This is by far the largest excise tax
amount reported by private foundations on Form 4720.
The number of foundations that filed Form 4720 for Tax
Year 2009 for failing to distribute the minimum required
amount decreased by 4.9 percent compared to Tax Year
2008. Figure J shows undistributed income subject to
the IRC section 4942 excise tax (“taxable undistributed
income”), as well as the amount of excise tax for Tax
Year 2009, by asset size. In all, 1,285 private foundations reported a total of $20.8 million of taxable undistributed income for Tax Year 2009. Over two-thirds, or
$14.1 million, of this total was undistributed income from
Tax Year 2008, while the remaining $6.7 million was
undistributed income from years prior to Tax Year 2008.
While smaller foundations were more likely to have some
amount of taxable undistributed income, the average
amount increased for larger foundations. For example,
the average amount of taxable undistributed income was
$16,212 for all private foundations, while the average was
$6,722 for private foundations with less than $1 million
of total assets and $165,467 for private foundations with
$10 million or more of total assets.
123

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure I
Domestic Nonoperating Private Foundations: Selected Percentile Distribution of Payout Rates, by Size
of End-of-Year Fair Market Value of Total Assets, Tax Year 2008
Payout rate
(percentage)
30.0
27.5
25.0
22.5
20.0
17.5
15.0
12.5

Median payout rate
for all foundations: 6.2

10.0
7.5
5.0
2.5
0.0
P5

P10

P15

P20

P25

P30

P35

P40

P45

P50
(Median)

P55

P60

P65

P70

P75

Percentile
All foundations

Less than $1 million

$1 million less than $10 million

$10 million less than $50 million

$50 million less than $100 million

$100 million or more

Domestic Nonoperating Private Foundations: Selected Percentile Distribution of Payout Rates, by Size
of End-of-Year Fair Market Value of Total Assets, Tax Year 2009
Payout rate
(percentage)
30
0
30.0
27.5
25.0
22.5
20.0
17.5
15.0
Median payout rate
for all foundations: 6.2

12.5
10.0
7.5
5.0
2.5
0.0
P5

P10

P15

P20

P25

P30

P35

P40

P45

P50
(Median)

P55

P60

P65

P70

Percentile

124

All foundations

Less than $1 million

$1 million less than $10 million

$10 million less than $50 million

$50 million less than $100 million

$100 million or more

P75

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure J
IRC Section 4942 Undistributed Income Tax Reported by Domestic Private Foundations on Form 4720,
by Size of End-of-Year Fair Market Value of Total Assets, Tax Year 2009
[Money amounts are in thousands of dollars]

Undistributed income subject to tax [2]
Total

Asset size [1]

All foundations
Less than $1,000,000

Number
of returns
(1)

Tax years prior to 2008
Amount

Number
of returns

(2)

(3)

Tax Year 2008

Total tax

Amount

Number
of returns

Amount

(4)

(5)

(6)

(7)

1,285

20,833

409

6,715

1,141

14,118

6,250

978

6,574

351

2,452

850

4,122

1,973

$1,000,000 less than $10,000,000

277

9,295

55

2,585

262

6,710

2,788

$10,000,000 less than $50,000,000

** 30

** 4,964

** 3

** 1,678

** 29

** 3,285

** 1,489

$50,000,000 less than $100,000,000

**

**

**

**

**

**

**

$100,000,000 or more

**

**

**

**

**

**

**

** Data combined to prevent disclosure of specific taxpayer data.
[1] Foundations were assigned to asset-size classes based on the reported current dollar end-of-year fair market value of total assets.
[2] Data are compiled from Schedule B of Forms 4720 filed during Calendar Years 2010 and 2011 by domestic private foundations only.

Generally, undistributed income was taxed at a rate
of 30 percent.11 In some cases, including allowances for
5-year “start-up” periods for new foundations and certain
types of organizational transitions or terminations, Tax
Year 2008 undistributed income was not subject to the
IRC section 4942 excise tax. The $6.3 million of taxes on
undistributed income represented 62.7 percent of all private foundation excise taxes reported on Form 4720 for
Tax Year 2009. The average amount of tax on undistributed income reported by foundations was $4,864; this average ranged from roughly $2,000 for the smallest foundations to close to $50,000 for the largest foundations.

Self-Dealing Taxes Under IRC Section 4941
For Tax Year 2009, there were 107 Forms 4720 filed by
private foundations reporting a total of 294 acts of selfdealing. In total, these acts involved $14.9 million, up
from the $10.6 million reported for Tax Year 2008. The
average amount of each self-dealing act was $51,000.
The amount of self-dealing tax is calculated as a percentage of the amount involved in the self-dealing act. For
each act, an initial 10-percent tax per year is imposed on
the self-dealer, while an initial 5-percent tax per year is
imposed on the foundation manager.12 For Tax Year 2009,
self-dealing taxes totaled $1.7 million and represented
the second largest excise tax amount reported by private
foundations on Form 4720.

Acts of self-dealing are classified into five categories
on Form 4720, as shown in Figure K. For Tax Year 2009,
the most commonly reported act of self-dealing was
borrowing money from, lending money to, or otherwise
extending credit to disqualified persons. These activities
accounted for 34.4 percent of self-dealing acts and 18.5
percent of the total self-dealing tax amount. The second
most frequently reported act of self-dealing, paying
compensation to or reimbursing a disqualified person,
accounted for 25.2 percent of self-dealing acts and 59.0
percent of the total self-dealing tax amount. The remaining three categories—transferring income or assets to a
disqualified person; selling, exchanging, or leasing property with a disqualified person; and furnishing goods,
services, or facilities to a disqualified person—together
accounted for 40.5 percent of all acts of self-dealing and
22.5 percent of the total self-dealing tax amount.

Additional Excise Taxes Under IRC Sections
4943–4945
Under IRC section 4943, private foundations whose
holdings in an unrelated corporation exceed allowed
amounts are subject to taxes on excess business holdings. Generally, foundations are limited to holding 20
percent of the voting stock of a corporation, reduced by
the percentage owned by disqualified persons. Private
foundations are subject to an initial 10-percent tax on

11 The excise tax on undistributed income is a “two-tier” tax, which consists of an initial tax and additional tax. If a private foundation has undistributed income for a reporting year that remains undistributed at the end of the following tax year, the initial tax of 30 percent automatically is imposed. Any organization that fails to distribute the
undistributed income within a designated “correction period” may be subject to the additional tax, which equals 100 percent of the amount of the undistributed income.
12 The total self-dealing tax imposed on foundation managers for all years in the taxable period is limited to $20,000.

125

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure K
IRC Section 4941 Excise Taxes on Self-Dealing Reported by Domestic Private
Foundations: Self-Dealing Acts as a Percentage of Total, by Type, Tax Year 2009 [1]
34.4%

Borrowing money from, lending money to, or otherwise
extending credit to a disqualified person

18.5%

25.2%

Paying compensation to, or paying or reimbursing the
expenses of, a disqualified person

59.0%
20.4%

Transferring any income or assets to a disqualified person

9.9%

10.2%

Selling, exchanging, or leasing of property with a disqualified
person

9
4%
9.4%

9.9%

Furnishing goods, services, or facilities to a disqualified
person

3.2%
0%

10%

20%

30%

40%

50%

60%

Percentage
Number [2]

Tax Amount

[1] Data are compiled from Schedule A of Forms 4720 filed during Calendar Years 2010 and 2011 by domestic private foundations only. Includes
initial tax, as well as tax on foundation managers, office directors, trustees, and other individuals.
[2] Percentages are based on the total number of reported acts of self-dealing, rather than the frequency of returns. A single return might have
included one or more acts of self-dealing.

excess business holdings. If a foundation fails to dispose of these holdings within a specified correction
period, it may be subject to a second-tier tax of 200
percent on the excess business holdings. This secondtier tax is not reported on Form 4720. For Tax Year 2009,
there were only five private foundations that reported a
total of nine taxable excess business holdings on Form
4720 (Figure L). These excess business holdings totaled
$13.7 million for an average of $1.5 million per holding.
For Tax Year 2009, taxes on excess business holdings
totaled $1.4 million and represented the third largest
excise tax amount reported by private foundations on
Form 4720.
IRC section 4944 imposes taxes on any organization that invests in a manner that endangers the organization’s ability to carry out its tax-exempt purposes.
126

A jeopardizing investment is one that shows a lack of
reasonable business care and prudence in providing for
the foundation’s short- and long-term fi nancial needs.
Foundations that hold large percentages of their portfolios in such investments, which may include highrisk, low-yield investments; securities purchased on the
margin; commodity futures; working interest in oil and
gas wells; “puts,” “calls,” and “straddles”; warrants; and
short sales, may be subject to the tax. High-risk, lowreturn “program-related” investments, which are investments made in support of a foundation’s charitable
purpose, are excluded from IRC section 4944 tax. For example, a foundation that, as one of its charitable activities,
provided loans to a small business in an economically
disadvantaged area would not be subject to the tax on the
loan transactions. There were no private foundations that

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure L

Figure M

IRC Section 4943 Excise Taxes on Excess
Business Holdings Reported by Domestic
Private Foundations on Form 4720, Tax Year
2009

IRC Section 4945 Excise Taxes on Taxable
Expenditures Reported by Domestic Private
Foundations on Form 4720, Tax Year 2009
[Money amounts are in whole dollars]

[Money amounts are in whole dollars]

Item

Percentage
of all
4720 filers

Number
or amount

Item

Percentage
of all
4720 filers

Number
or amount

Number of returns with taxable acts

98
153

6.6
8.8

3,183,424

6.0

Number of returns with taxable acts

5

0.3

Number of taxable acts

Number of taxable acts

9

0.5

Amount involved in act

Amount involved in act

13,713,712

26.0

Mean amount involved in act

20,807

N/A

1,523,746

N/A

Median amount involved in act

1,500

N/A

Mean amount involved in act
Median amount involved in act
Total reported tax

205,865

N/A

1,371,372

13.8

Mean tax amount per taxable act

152,375

N/A

Median tax amount per taxable act

20,587

N/A

N/A—Not applicable.
NOTE: Data are compiled from Schedules C of Forms 4720 filed by domestic private
foundations during Calendar Years 2010 and 2011. Includes initial tax on foundation
only.

reported IRC section 4944 excise taxes on jeopardizing
investments on Form 4720 for Tax Year 2009.
Under IRC section 4945, certain types of expenditures are designated as taxable. These include attempting to influence legislation or the outcome of a specific
election; providing a grant to an individual for travel,
study, or other similar purpose; or providing support for
any other than religious, charitable, scientific, literary, or
educational purposes. A foundation that provides a grant
to an organization other than a recognized charitable organization may also incur taxable expenditures, but may
avoid tax liability by exercising “expenditure responsibility” with respect to the grant. Expenditure responsibility requires the foundation to set up procedures to ensure
that the grant is spent solely for the purpose for which it
was made, provide reports from the grantee on how the
grant was spent, and fully disclose the expenditures to
the IRS. For Tax Year 2009, there were 98 private foundations that reported a total of 153 taxable expenditures
on Form 4720 (Figure M). These taxable expenditures
totaled $3.2 million for Tax Year 2009, with the mean
amount at just less than $21,000 and the median amount
at $1,500. For Tax Year 2009, the total tax on taxable
expenditures reported by private foundations on Form
4720 was a little more than $640,000.

Summary
Private foundations exempt under IRC section 501(c)(3)
filed 92,624 Forms 990-PF for Tax Year 2009, a 2.0-percent increase over the previous year. Total assets reported
by private foundations increased 10.5 percent between
Tax Years 2008 and 2009, from $532.9 billion to $588.5

Total reported tax

[1] 640,263

6.4

Mean tax amount per taxable act

4,185

N/A

Median tax amount per taxable act

375

N/A

N/A—Not applicable.
[1] This total amount differs from the rounded, detail amounts shown in Figure D.
NOTE: Data are compiled from Schedules E of Forms 4720 filed by domestic private
foundations during Calendar Years 2010 and 2011. Includes initial tax, as well as tax
on foundation managers, office directors, trustees, and other individuals.

billion. Over the same time period, total revenue increased by a smaller margin, 3.8 percent, from $50.3 billion to $52.2 billion. The amount of contributions, gifts,
and grants paid declined 5.6 percent between Tax Years
2008 and 2009. Nonoperating private foundations, which
primarily distributed grants in support of their charitable
purposes, represented the majority of filers.
Large foundations, those with assets of $50 million or more, represented 1.6 percent of filers, but held
more than two-thirds of the fair market value of total
assets reported by private foundations for Tax Year 2009.
Additionally, large foundations received the majority of
total revenue and distributed the majority of reported
contributions, gifts, and grants.
Although exempt from traditional income taxes, private foundations were required to report and pay excise
taxes under IRC sections 4940 through 4945. Domestic
private foundations reported $230.9 million in excise tax
liability for Tax Year 2009. The IRC section 4940 excise
tax on net investment income, $221.0 million, was the
largest component of excise taxes. This tax was reported
on Form 990-PF and was required for most private foundations that held investment assets. An additional $10.0
million in excise taxes, under IRC sections 4941-4945,
were reported on Forms 4720 by private foundations
and disqualified persons that engaged in prohibited activities for Tax Year 2009. The IRC section 4942 tax on
undistributed income, paid by nonoperating private foundations that failed to meet their charitable distribution
requirement for a previous tax year, was the largest private foundation excise tax reported on Forms 4720. This
excise tax totaled $6.3 million in Tax Year 2009. Taxes on

127

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

self-dealing, imposed on individuals under IRC section
4941, totaled $1.7 million and was the second-largest tax
reported on Forms 4720 for private foundations. The remaining taxes reported by private foundations on Forms
4720, described in IRC sections 4943-4945, totaled $2.0
million for Tax Year 2009.

Data Sources and Limitations
The Tax Year 2009 private foundation statistics presented
in this article are based on a sample of Tax Year 2009
Forms 990-PF that were filed with the Internal Revenue
Service. Organizations having accounting periods beginning in 2009 (and therefore ending between December
2009 and November 2010) that filed returns that posted
to the IRS Business Master File in Calendar Years 2010
and 2011 were included in the sample. Some part-year
returns were included in the samples for organizations
that changed their accounting periods, or filed initial or
fi nal returns. Over 72 percent of the domestic private
foundations in the sample had accounting periods covering Calendar Year 2009 or, in some cases, part-year
periods that ended in December 2009.
The Tax Year 2009 sample was stratified based on
both the size of fair market value of total assets and the
type of organization (either a private foundation or an
IRC section 4947(a)(1) charitable trust). To accomplish
this, 100 percent of returns filed for foundations with fair
market asset value of $10 million or more for Tax Year
2009, or 6.5 percent of all foundations, were included in
the samples, since these organizations represented the
vast majority of financial activity. Additionally, Forms
990-PF filed by foundations that also filed a Form 4720
for Tax Year 2009 during the 2-year sampling period
were selected at a rate of 100 percent. The remaining
foundation population was randomly selected for the
sample at various rates of less than 100 percent depending on asset size. The realized sampling rates for each
asset-size category are included in Figure N. Figure O
shows the magnitude of sampling error for selected items
for Tax Year 2009, measured by coefficients of variation.
Efforts were made to verify that organizations selected into the sample were properly classified as foundations or trusts. The relatively few foundations in the
sample that were incorrectly selected as trusts were ultimately treated as foundations for these statistics, and
the relatively few trusts incorrectly sampled as foundations were also reclassified. However, the weights used
for these organizations were based on the original sample
selection classification.
For Tax Year 2009, there were 10,652 foundation returns in the sample selected from a population of 96,563.
128

The difference between the actual population of Forms
990-PF records that posted to the IRS Business Master
File during 2010 and 2011 and the estimated population
of domestic foundation returns as published in this article results from sample code changes and the effects
of returns that were “rejected” from the sample as part
of the editing process. For example, foreign returns and
duplicate filings by a single organization were included
in the actual population of Forms 990-PF filed but were
rejected from the SOI sample.

Figure N
Realized Sampling Rates for Private
Foundation Returns, by Size of End-of-Year
Fair Market Value of Total Assets, Tax Year
2009
Asset size

Less than $125,000
$125,000 under $400,000
$400,000 under $1,000,000
$1,000,000 under $2,500,000
$2,500,000 under $10,000,000
$10,000,000 or more

Realized
sampling rate
(percentage)
1.0
1.9
2.2
6.5
10.0
100.0

The IRC sections 4941-4945 excise tax statistics included in this article were obtained from the combined
population of Forms 4720 filed by private foundations
for Tax Year 2009 and processed during Calendar Years
2010 and 2011. Of the 3,838 Forms 4720 received from
private foundations, charitable trusts, or disqualified persons over the 2 calendar years, some 1,770 were filed for
Tax Year 2009. Returns filed by charitable trusts were
excluded from the analysis; data from the 1,498 private
foundations and associated disqualified persons are included in these statistics. Due to IRS processing procedures, in a small number of cases, a return filed by an
individual whose accounting period differed from that of
his or her associated private foundation might have been
excluded from the population of filers.
The data presented were obtained from returns as
originally filed with IRS. In most cases, changes made
to the original return because of administrative processing, audit procedures, or a taxpayer amendment were not
captured in the statistics. The data were subject to comprehensive testing and correction procedures in order to
ensure statistical reliability and validity. A general discussion of the reliability of estimates based on samples,
methods for evaluating both the magnitude of sampling
and nonsampling error, and the precision of sample

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Figure O
Coefficients of Variation for Domestic Private Foundations, Selected Items, by Size of End-of-Year Fair
Market Value of Total Assets, Tax Year 2009
Asset size
Item

Total

Assets
zero or
unreported

$1
under
$100,000

$100,000
under
$1,000,000

$1,000,000
under
$10,000,000

$10,000,000
or more

(1)

(2)

(3)

(4)

(5)

(6)

Number of returns

0.00

27.82

2.55

1.62

0.83

N/A

Total revenue

2.18

64.35

35.18

31.85

7.99

N/A

Contributions, gifts, and grants received

2.60

62.42

36.00

33.65

8.34

N/A

Dividends and interest from securities

0.38

79.11

13.37

3.45

2.13

N/A

Net gain (less loss) from sales of assets

3.36

70.26

62.44

25.52

9.95

N/A

1.96

43.94

30.70

24.60

5.03

N/A

Disbursements for charitable purposes

2.21

44.91

34.27

27.44

4.87

N/A

Contributions, gifts, and grants paid

1.70

47.14

38.69

16.73

4.84

N/A

Excess of revenue over expenses

11.46

49.76

47.16

20.43

25.26

N/A

Net investment income

0.79

70.49

39.84

10.89

5.09

N/A

Excise tax on net investment income

0.82

70.18

34.17

9.86

4.77

N/A

Total assets (book value)

0.16

*

12.28

1.73

1.07

N/A

Investment assets, total

0.17

*

15.30

2.13

1.20

N/A

Investments in securities, total

0.29

*

21.63

3.47

1.72

N/A

Government obligations

0.63

*

43.94

12.50

6.37

N/A

Corporate stock

0.34

*

24.86

4.16

1.96

N/A

Corporate bonds

0.71

*

31.63

8.39

3.90

N/A

Total assets (fair market value)

0.18

*

6.79

1.26

1.32

N/A

Investment assets, total

0.20

*

8.58

1.74

1.49

N/A

Investments in securities, total

0.34

*

13.20

3.06

2.14

N/A

Government obligations

0.64

*

44.70

12.47

6.35

N/A

Corporate stock

0.42

*

14.50

3.64

2.54

N/A

Corporate bonds

0.70

*

32.06

8.41

3.81

N/A

Total expenses

Net worth (book value)

0.17

89.23

35.65

1.81

1.10

N/A

Noncharitable-use assets

0.21

64.09

8.94

1.65

1.48

N/A

Minimum investment return

0.22

64.09

8.96

1.68

1.49

N/A

Distributable amount

0.23

64.77

10.15

1.95

1.61

N/A

Qualifying distributions

2.13

44.91

34.16

27.30

4.86

N/A

Undistributed income for current year

0.85

9.33

22.78

6.71

4.80

N/A

Excess distributions carryover to next year

3.48

60.96

30.77

12.46

10.18

N/A

* No money amount reported.
N/A—Not applicable because the realized sampling rate was 100 percent. See Figure N.

estimates can be found in SOI Sampling Methodology
and Data Limitations later in this issue of the SOI Bulletin,
or at http://www.irs.gov/pub/irs-soi/sampling.pdf.

Explanation of Selected Terms
The following explanations describe terms as they applied to private foundations:
Disbursements for charitable purposes—These disbursements are outlays made exclusively in support of a
foundation’s tax-exempt purpose and include grants paid
and operating and administrative expenses. They were
the largest component of “qualifying distributions” for

Tax Year 2009. The total of disbursements for charitable
purposes was reported on Form 990-PF, Part I, line 26,
column (d).
Disqualified person—In general, a disqualified
person is a substantial contributor; a foundation manager;
a person who owns more than 20 percent of a corporation,
partnership, trust, or unincorporated enterprise that is
itself a substantial contributor; or a family member of a
disqualified person.
Distributable (payout) amount—This is the minimum payout amount that is required to be distributed by
nonoperating foundations by the end of the tax year that

129

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

130

follows the tax year for which the return was filed. For
example, foundations were required to distribute their
Tax Year 2008 amounts before the end of Tax Year 2009.
Failure to distribute income within this period results
in a 30-percent excise tax on the undistributed portion.
The distributable amount equals 5 percent of the net
value of noncharitable-use assets, called the “minimum
investment return,” minus the excise tax on net investment income, plus or minus other adjustments, either allowed or required (see “Net adjustments to distributable
amount” in this section).
Minimum investment return—The minimum investment return is used as the base for calculating the
“distributable amount.” This is the aggregate fair market
value of assets not used for charitable purposes, less both
the indebtedness incurred to acquire these assets and the
cash held for charitable activities, multiplied by 5 percent.
Minimum investment return was reported on Form 990PF, Part X, line 6.
Net adjustments to distributable amount—The
“distributable amount” is increased by recoveries of
amounts previously treated as qualifying distributions.
Additionally, certain organizations with governing instruments that require the accumulation of income are
instructed to deduct the accumulated income from their
distributable amount. These adjustments are allowed
only for foundations organized before May 27, 1969,
whose governing instrument requires such accumulation because State Courts would not allow the organization to change the governing instrument. Recoveries on
amounts treated as qualifying distributions and the deduction for accumulated income were reported on Form
990-PF, Part XI, lines 4 and 6, respectively.
Net investment income—This equals gross investment income less allowable deductions. Interest, dividends, rents, royalties, net income from realized capital gains, and, beginning in 2006, certain other similar
income from investments are included in net investment
income. Any investment income derived from unrelated
trade or business activities, and therefore subject to the
“unrelated business income” tax and reported on Form
990-T, Exempt Organization Business Income Tax Return,
is excluded. Net investment income was reported on
Form 990-PF, Part I, line 27b, column (b).
Net value of noncharitable-use assets—An asset is
considered a noncharitable-use asset if it is not used in
carrying out a charitable, educational, or other similar
function that relates directly to the tax-exempt status of
the foundation. Examples include the fair market values
of securities and rental property owned by the foundation for investment purposes. For purposes of calculating the “minimum investment return,” valuation

methods for noncharitable-use assets reported in this
section differ from those used to report the end-of-year
fair market values for all assets in Part II. The average, rather than end-of-year, fair market values of cash
and securities that were not used or held for use for
charitable purposes during the tax year is derived and
used in this calculation. With certain exceptions, other
assets included in this calculation are valued annually,
but not necessarily based on the end-of-year value. The
fair market values of noncharitable-use assets may reflect reductions due to certain characteristics associated with those assets, such as lack of marketability or
blockage. The net value of noncharitable-use assets is
reduced by acquisition indebtedness and cash deemed
held for charitable purposes; the latter reduction is generally limited to 1.5 percent of noncharitable-use assets
less acquisition indebtedness. Thus, the net value of
noncharitable-use assets, which was reported on Form
990-PF, Part X, line 5, as an element of the “minimum
investment return” calculation, differed from the balance sheet-derived fair market value of total assets, as
reported on Part II, line 16, column (c), which equaled
the total end-of-year value for all assets held by the
foundation.
Nonoperating foundations—These are foundations
that generally carried on their charitable activities in an
indirect manner by making grants to other organizations
directly engaged in charitable activities, in contrast to operating foundations that engaged in charitable activities
themselves. However, for Tax Year 2009, some nonoperating foundations may have been actively involved in
charitable programs of their own, in addition to making
grants. For example, a foundation initially organized as
operating that was unable to meet the operating foundation requirements for Tax Year 2009 could have continued its direct charitable activities. Such an organization
could have directed expenditures made for these direct
charitable activities, as well as expenditures made for
the disbursement of contributions, gifts, and grants and
other indirect charitable activities, toward meeting the
required distribution requirement.
Operating foundations—These foundations generally expended their income for direct, active involvement in a tax-exempt activity. Operating foundations
were exempted from the income distribution requirement and related excise taxes that were applicable to
their nonoperating counterparts. Individual taxpayers
could deduct contributions to operating foundations
on their individual income tax returns; the deduction
could not exceed 50 percent of a donor’s “adjusted gross
income” (as opposed to 30 percent for contributions to
nonoperating foundations).

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Private foundation—A private foundation is defined
in IRC section 501(c)(3) as a nonprofit organization with
a narrow source of funds that operated or supported
educational, scientific, charitable, religious, and other
programs dedicated to improving the general welfare of
society. A private foundation was an organization that
qualified for tax-exempt status under IRC section 501(c)
(3) but was not (1) a church, school, hospital, or medical
research organization; (2) an organization with broad
public support in the form of contributions or income
from tax-exempt activities; (3) an organization that was
operated by, or in connection with, any of the above described organizations; or (4) an organization that conducted tests for public safety. The primary difference
between a private foundation and other organizations
exempt under 501(c)(3) was the source of the organization’s funding. An individual, a family, or a corporation
typically funded foundations, while most other tax-exempt organizations received funds from a large number
of sources among the general public.
Qualifying distributions—Qualifying distributions
include disbursements for charitable purposes (grants,
direct expenditures to accomplish charitable purposes,
and charitable-purpose operating and administrative
expenses); amounts paid to acquire assets used directly to accomplish tax-exempt functions; charitable
program-related investments; and amounts set aside for
future charitable projects. Qualifying distributions may
be credited against a foundation’s obligation to pay out
its “distributable amount.” Total qualifying distributions
were reported on Form 990-PF, Part XII, line 4.
Set-asides—Amounts set-aside for specific charitable purposes can be treated as qualifying distributions
only if the foundation establishes to the satisfaction of
the IRS that the amount will be paid for the specific
project within 60 months from the date of the fi rst setaside and if the foundation meets either the suitability
test or the cash distribution test. To meet the suitability
test, a foundation must receive prior approval from the
IRS and must demonstrate that the project can be better

accomplished by a set-aside than by an immediate payment of funds. To meet the cash distribution test under
IRC section 4942(g)(2)(B)(ii), a foundation must attach
a distribution schedule to its annual return for the year
of the set-aside and for each subsequent year until the
set-aside amount has been distributed. Set-asides were
reported on Form 990-PF, Part XII, lines 3a and 3b.
Total assets—This is the sum of all assets reported
in the foundation’s balance sheet, shown at both book
value and fair market value. Total assets were reported
on Form 990-PF, Part II, line 16, columns (a) beginningof-year book value, (b) end-of-year book value, and (c)
end-of-year fair market value.
Total revenue—This is the sum of gross contributions, gifts, and grants received; interest on savings and
temporary cash investments; dividends and interest from
securities; net gain (or loss) from sales of assets (mostly
investment assets, but also charitable-use assets); gross
rents and royalties; gross profit (or loss) from business
activities; and other income (such as royalty income,
program-related investment income, interest earned on
assets used for charitable purposes, and imputed interest
on distributions deferred interest). Total revenue items,
which included both investment and charitable-use items,
were reported on Form 990-PF, Part I, line 12, column (a).
Undistributed income—This is the portion of the
required “distributable amount” still undistributed after
the sum of current-year qualifying distributions and any
excess distributions carried over from prior years are
subtracted. This item was reported on Form 990PF, Part
XIII, line 6f, column (d). Under IRC section 4942, nonoperating private foundations that did not pay out an amount
equal to the Tax Year 2008 “distributable amount” by the
end of Tax Year 2009 were subject to an excise tax on the
undistributed amount. As a result of legislation included
in the Pension Protection Act of 2006, the initial tax on
undistributed income was increased from 15 percent to
30 percent of the undistributed amount for taxable years
beginning after August 17, 2006. The tax, which is automatically imposed, is reported on Form 4720.

131

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Selected sources of revenue
Total revenue
Type of foundation, asset size

Number
of returns

(1)

Contributions, gifts,
and grants received

Dividends and interest
from securities

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(2)

(3)

(4)

(5)

(6)

(7)

All foundations
Total

92,624

89,575

52,179,124

37,310

42,380,197

66,218

Zero or unreported

1,244

1,135

65,993

618

67,947

* 207

9,029,813
* 495

$1 under $100,000

25,562

22,851

1,449,584

13,508

1,408,387

9,391

10,604

$100,000 under $1,000,000

35,077

34,925

2,708,381

12,113

2,535,912

28,175

275,200

$1,000,000 under $10,000,000

24,520

24,448

6,840,794

8,517

5,849,505

22,599

1,536,171

$10,000,000 under $25,000,000

3,429

3,424

5,993,532

1,362

5,018,182

3,219

985,992

$25,000,000 under $50,000,000

1,347

1,347

4,187,036

525

3,563,740

1,258

832,271

$50,000,000 under $100,000,000

740

739

3,599,795

324

2,954,343

702

886,989

$100,000,000 or more

705

705

27,334,010

342

20,982,179

667

4,502,092

Total

84,660

81,881

44,571,261

31,898

36,149,987

63,127

8,660,573

Zero or unreported

1,038

1,032

62,394

* 516

* 64,340

* 207

* 495

$1 under $100,000

21,775

19,167

1,284,842

10,745

1,260,501

8,367

9,577

Nonoperating foundations

$100,000 under $1,000,000

33,110

33,004

1,611,366

11,005

1,558,415

27,536

267,395

$1,000,000 under $10,000,000

23,021

22,964

5,625,751

7,482

5,063,127

21,556

1,488,304

$10,000,000 under $25,000,000

3,158

3,156

4,093,377

1,150

3,309,234

3,024

944,221

$25,000,000 under $50,000,000

1,237

1,237

3,158,879

432

2,769,831

1,175

794,990

$50,000,000 under $100,000,000

682

681

2,864,872

279

2,309,608

651

838,825

$100,000,000 or more

639

639

25,869,780

288

19,814,931

611

4,316,766

Total

7,964

7,694

7,607,864

5,412

6,230,210

3,091

369,241

Zero or unreported

* 206

* 103

* 3,598

* 102

* 3,607

*0

*0

$1 under $100,000

3,787

3,684

164,742

2,763

147,887

1,024

1,027

Operating foundations

$100,000 under $1,000,000

1,967

1,921

1,097,015

1,107

977,497

638

7,805

$1,000,000 under $10,000,000

1,499

1,484

1,215,043

1,035

786,379

1,043

47,867

$10,000,000 under $25,000,000

271

268

1,900,156

212

1,708,948

195

41,771

$25,000,000 under $50,000,000

110

110

1,028,157

93

793,909

83

37,281

$50,000,000 under $100,000,000

58

58

734,923

45

644,735

51

48,163

$100,000,000 or more

66

66

1,464,230

54

1,167,248

56

185,326

8,853,960

Grantmaking foundations
Total

77,316

76,312

45,617,832

29,024

36,754,171

61,546

Zero or unreported

823

823

64,379

* 410

* 66,024

* 207

* 495

$1 under $100,000

16,642

15,718

1,156,386

8,950

1,167,380

7,583

9,407

$100,000 under $1,000,000

31,156

31,108

1,588,654

10,020

1,451,741

26,522

265,001

$1,000,000 under $10,000,000

22,838

22,807

5,512,295

7,357

4,837,705

21,639

1,494,484

$10,000,000 under $25,000,000

3,207

3,207

5,084,167

1,199

4,327,528

3,067

958,312

$25,000,000 under $50,000,000

1,262

1,262

3,663,981

466

3,206,661

1,202

810,558

$50,000,000 under $100,000,000

709

709

3,337,912

304

2,742,588

682

872,626

$100,000,000 or more

677

677

25,210,058

317

18,954,545

644

4,443,077

Footnotes at end of table.

132

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Selected sources of revenue
Total revenue
Type of foundation, asset size

Number
of returns

(1)

Contributions, gifts,
and grants received

Dividends and interest
from securities

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(2)

(3)

(4)

(5)

(6)

(7)

Grantmaking-nonoperating foundations
Total

73,299

72,310

40,910,577

26,579

32,807,562

59,526

Zero or unreported

720

720

60,781

* 308

* 62,417

* 207

8,591,199
* 495

$1 under $100,000

14,698

13,773

1,052,466

7,722

1,065,319

6,866

8,576

$100,000 under $1,000,000

30,207

30,159

1,489,963

9,518

1,371,093

25,983

257,652

$1,000,000 under $10,000,000

22,074

22,058

4,798,186

6,951

4,359,451

21,079

1,469,068

$10,000,000 under $25,000,000

3,090

3,090

3,669,637

1,107

2,983,700

2,978

937,056

$25,000,000 under $50,000,000

1,206

1,206

2,795,840

418

2,484,876

1,160

789,825

$50,000,000 under $100,000,000

672

672

2,724,824

273

2,184,634

647

837,041

$100,000,000 or more

632

632

24,318,881

282

18,296,073

606

4,291,487

Total

4,017

4,002

4,707,254

2,446

3,946,610

2,020

262,760

Zero or unreported
$1 under $100,000

* 103
1,945

* 103
1,945

* 3,598
103,920

* 102
1,229

* 3,607
102,061

*0
* 717

*0
* 832

Grantmaking-operating foundations

$100,000 under $1,000,000

950

950

98,691

503

80,648

539

7,349

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

764
117

749
117

714,109
1,414,530

406
92

478,254
1,343,828

560
89

25,415
21,256

$25,000,000 under $50,000,000

56

56

868,141

48

721,785

42

20,733

$50,000,000 under $100,000,000

37

37

613,088

31

557,954

35

35,585

$100,000,000 or more

45

45

891,177

35

658,472

38

151,590

Footnotes at end of table.

133

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Selected sources of
revenue—continued
Total expenses
Type of foundation, asset size

Net gain (less loss)
from sales of assets

Excess of revenue
(less loss)
over expenses

Net investment
income

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(8)

(9)

(10)

(11)

(12)

(13)

(14)

(15)

All foundations
Total

53,765

-5,556,396

90,797

56,184,890

90,682

-4,005,766

71,789

17,574,446

Zero or unreported

* 310

* -3,371

1,239

108,573

830

-42,580

* 515

* 1,155

$1 under $100,000

5,725

-44,093

24,179

1,765,282

24,211

-315,699

11,806

35,863

$100,000 under $1,000,000

21,806

-370,068

34,822

3,514,107

34,923

-805,726

30,811

529,566

$1,000,000 under $10,000,000

20,340

-1,588,872

24,358

8,424,076

24,503

-1,583,282

22,807

2,475,461

$10,000,000 under $25,000,000

3,022

-649,870

3,415

6,224,874

3,424

-231,342

3,224

1,858,940

$25,000,000 under $50,000,000

1,216

-840,796

1,341

4,861,974

1,346

-674,938

1,256

1,404,006

$50,000,000 under $100,000,000

685

-734,093

738

4,652,571

739

-1,052,777

700

1,654,266

$100,000,000 or more

662

-1,325,233

705

26,633,432

705

700,578

670

9,615,190

Nonoperating foundations
Total

51,750

-5,152,165

82,996

47,967,472

82,928

-3,396,212

67,422

16,612,123

Zero or unreported

* 309

* -3,362

1,033

100,003

727

-37,608

* 515

* 1,155

$1 under $100,000

5,315

-43,895

20,494

1,613,333

20,526

-328,491

10,576

35,074

$100,000 under $1,000,000

21,422

-370,675

32,901

2,396,205

32,956

-784,839

29,316

513,426

$1,000,000 under $10,000,000

19,496

-1,562,810

22,869

7,309,971

23,005

-1,684,220

21,589

2,390,407

$10,000,000 under $25,000,000

2,836

-636,386

3,148

4,473,829

3,156

-380,452

3,002

1,779,843

$25,000,000 under $50,000,000

1,133

-808,983

1,231

3,876,235

1,237

-717,356

1,167

1,283,276

$50,000,000 under $100,000,000

635

-695,080

681

3,989,349

681

-1,124,477

649

1,575,333

$100,000,000 or more

604

-1,030,974

639

24,208,548

639

1,661,232

607

9,033,610

962,323

Operating foundations
Total

2,015

-404,231

7,800

8,217,418

7,754

-609,554

4,367

Zero or unreported

*1

* -9

* 206

* 8,570

* 103

* -4,972

*0

*0

$1 under $100,000

* 409

* -199

3,685

151,950

3,685

12,792

1,230

789

$100,000 under $1,000,000

385

608

1,921

1,117,902

1,967

-20,887

1,495

16,140

$1,000,000 under $10,000,000

843

-26,062

1,489

1,114,104

1,498

100,939

1,217

85,054

$10,000,000 under $25,000,000

186

-13,484

267

1,751,045

268

149,110

222

79,097

$25,000,000 under $50,000,000

83

-31,813

110

985,740

109

42,417

89

120,729

$50,000,000 under $100,000,000

50

-39,012

57

663,222

58

71,700

51

78,933

$100,000,000 or more

58

-294,259

66

2,424,884

66

-960,654

63

581,580

Grantmaking foundations
Total

50,718

-5,380,910

77,213

52,946,300

76,957

-7,328,469

65,088

17,202,680

Zero or unreported

* 309

* -3,050

823

101,697

619

-37,318

* 411

* 1,153

$1 under $100,000

4,773

-30,394

16,540

1,522,122

16,540

-365,737

9,337

34,495

$100,000 under $1,000,000

20,690

-279,856

31,156

2,432,879

31,107

-844,226

28,175

513,327

$1,000,000 under $10,000,000

19,598

-1,536,849

22,838

7,653,242

22,838

-2,140,947

21,601

2,407,917

$10,000,000 under $25,000,000

2,875

-665,977

3,207

5,665,666

3,205

-581,499

3,050

1,789,945

$25,000,000 under $50,000,000

1,164

-826,647

1,262

4,582,599

1,261

-918,618

1,194

1,369,726

$50,000,000 under $100,000,000

669

-724,983

709

4,548,813

709

-1,210,901

676

1,629,763

$100,000,000 or more

640

-1,313,155

677

26,439,282

677

-1,229,224

643

9,456,353

Footnotes at end of table.

134

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Selected sources of
revenue—continued
Total expenses
Type of foundation, asset size

Net gain (less loss)
from sales of assets

Excess of revenue
(less loss)
over expenses

Net investment
income

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(8)

(9)

(10)

(11)

(12)

(13)

(14)

(15)

Grantmaking-nonoperating foundations
Total

49,409

-5,013,126

73,196

47,063,715

73,044

-6,153,138

62,728

16,506,201

Zero or unreported

* 308

* -3,042

720

98,067

618

-37,286

* 411

* 1,153

$1 under $100,000

4,466

-30,174

14,595

1,430,954

14,595

-378,489

8,620

34,064

$100,000 under $1,000,000

20,404

-280,615

30,207

2,330,948

30,158

-840,985

27,392

498,479

$1,000,000 under $10,000,000

19,085

-1,514,870

22,074

6,912,932

22,074

-2,114,746

20,964

2,365,252

$10,000,000 under $25,000,000

2,792

-647,086

3,090

4,360,636

3,089

-690,999

2,952

1,753,112

$25,000,000 under $50,000,000

1,120

-814,076

1,206

3,779,242

1,206

-983,402

1,146

1,273,196

$50,000,000 under $100,000,000

633

-694,013

672

3,963,738

672

-1,238,914

642

1,573,373

$100,000,000 or more

601

-1,029,252

632

24,187,198

632

131,683

600

9,007,573

Total

1,309

-367,784

4,017

5,882,585

3,913

-1,175,331

2,360

696,479

Zero or unreported
$1 under $100,000

*1
* 307

* -9
* -220

* 103
1,945

* 3,630
91,168

*1
1,945

* -32
12,752

*0
* 717

*0
* 432

$100,000 under $1,000,000

* 286

* 760

950

101,932

950

-3,240

782

14,849

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

513
83

-21,979
-18,891

764
117

740,310
1,305,030

764
116

-26,201
109,500

637
98

42,666
36,833

Grantmaking-operating foundations

$25,000,000 under $50,000,000

44

-12,571

56

803,357

55

64,784

48

96,530

$50,000,000 under $100,000,000

36

-30,971

37

585,075

37

28,013

34

56,390

$100,000,000 or more

39

-283,903

45

2,252,084

45

-1,360,907

43

448,780

Footnotes at end of table.

135

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Disbursements for
exempt purposes

Contributions, gifts,
and grants paid [1]

Excise tax on
net investment income

Total assets
(book value) [2]

Type of foundation, asset size

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(16)

(17)

(18)

(19)

(20)

(21)

(22)

(23)

All foundations
Total

84,763

48,061,907

77,316

40,913,645

66,743

220,966

Zero or unreported

1,028

104,909

823

99,052

* 412

* 12

91,380 550,893,728
0

0

$1 under $100,000

20,473

1,565,324

16,642

1,347,324

8,489

431

25,562

960,239

$100,000 under $1,000,000

33,217

3,114,001

31,156

2,076,294

29,781

7,207

35,077

14,513,181

$1,000,000 under $10,000,000

23,895

7,185,970

22,838

6,233,279

22,348

34,571

24,520

72,278,063

$10,000,000 under $25,000,000

3,382

5,531,227

3,207

4,708,750

3,151

25,994

3,429

48,886,322

$25,000,000 under $50,000,000

1,331

4,328,691

1,262

3,761,612

1,223

18,985

1,347

42,949,965

$50,000,000 under $100,000,000

735

4,229,051

709

3,681,854

686

21,958

740

47,566,969

$100,000,000 or more

701

22,002,734

677

19,005,479

653

111,808

705 323,738,988

83,622 509,852,492

Nonoperating foundations
Total

77,854

42,152,689

73,299

38,422,260

63,424

211,119

Zero or unreported

822

96,342

720

95,426

* 412

* 12

0

0

$1 under $100,000

17,403

1,477,705

14,698

1,328,737

7,772

416

21,775

863,425

$100,000 under $1,000,000

31,448

2,139,433

30,207

2,040,290

28,442

6,963

33,110

13,842,937

$1,000,000 under $10,000,000

22,510

6,373,787

22,074

5,962,341

21,390

33,621

23,021

67,830,512

$10,000,000 under $25,000,000

3,131

3,989,437

3,090

3,665,651

2,990

25,197

3,158

45,024,031

$25,000,000 under $50,000,000

1,226

3,540,566

1,206

3,226,822

1,163

17,821

1,237

39,590,834

$50,000,000 under $100,000,000

678

3,659,523

672

3,270,193

647

21,087

682

43,968,950

$100,000,000 or more

635

20,875,897

632

18,832,800

608

106,002

639 298,731,804

Total

6,909

5,909,217

4,017

2,491,385

3,319

9,847

7,758

Zero or unreported

* 206

* 8,568

* 103

* 3,626

*0

*0

*0

*0

$1 under $100,000

3,070

87,619

1,945

18,587

* 717

* 14

3,787

96,815

Operating foundations
41,041,235

$100,000 under $1,000,000

1,769

974,568

950

36,003

1,339

244

1,967

670,245

$1,000,000 under $10,000,000

1,385

812,184

764

270,938

958

950

1,499

4,447,550

$10,000,000 under $25,000,000

251

1,541,789

117

1,043,099

161

797

271

3,862,292

$25,000,000 under $50,000,000

105

788,125

56

534,790

60

1,164

110

3,359,131

$50,000,000 under $100,000,000

57

569,527

37

411,661

39

871

58

3,598,019

$100,000,000 or more

66

1,126,838

45

172,680

45

5,806

66

25,007,184

Grantmaking foundations
Total

77,316

45,928,225

77,316

40,913,645

61,683

215,971

Zero or unreported

823

99,968

823

99,052

* 411

* 12

0

0

$1 under $100,000

16,642

1,442,813

16,642

1,347,324

6,868

407

16,642

701,499

$100,000 under $1,000,000

31,156

2,189,559

31,156

2,076,294

27,504

6,937

31,156

13,131,764

$1,000,000 under $10,000,000

22,838

6,874,783

22,838

6,233,279

21,396

33,867

22,838

67,862,770

$10,000,000 under $25,000,000

3,207

5,144,359

3,207

4,708,750

3,019

25,071

3,207

45,836,655

$25,000,000 under $50,000,000

1,262

4,141,951

1,262

3,761,612

1,183

18,657

1,262

40,317,182

$50,000,000 under $100,000,000

709

4,165,913

709

3,681,854

667

21,745

709

45,691,159

$100,000,000 or more

677

21,868,879

677

19,005,479

634

109,274

677 317,703,162

Footnotes at end of table.

136

76,492 531,244,192

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Disbursements for
exempt purposes

Contributions, gifts,
and grants paid [1]

Excise tax on
net investment income

Total assets
(book value) [2]

Type of foundation, asset size

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(16)

(17)

(18)

(19)

(20)

(21)

(22)

(23)

Grantmaking-nonoperating foundations
Total

73,299

41,905,689

73,299

38,422,260

59,660

209,241

Zero or unreported

720

96,341

720

95,426

* 411

* 12

72,578 501,499,411
0

0

$1 under $100,000

14,698

1,390,628

14,698

1,328,737

6,355

399

14,698

640,835

$100,000 under $1,000,000

30,207

2,126,808

30,207

2,040,290

26,723

6,709

30,207

12,712,318

$1,000,000 under $10,000,000

22,074

6,343,553

22,074

5,962,341

20,841

33,257

22,074

65,746,584

$10,000,000 under $25,000,000

3,090

3,955,706

3,090

3,665,651

2,943

24,684

3,090

44,094,180

$25,000,000 under $50,000,000

1,206

3,466,279

1,206

3,226,822

1,144

17,638

1,206

38,575,832

$50,000,000 under $100,000,000

672

3,651,350

672

3,270,193

641

21,052

672

43,216,031

$100,000,000 or more

632

20,875,024

632

18,832,800

601

105,489

632 296,513,632

Total

4,017

4,022,536

4,017

2,491,385

2,023

6,730

3,914

29,744,781

Zero or unreported
$1 under $100,000

* 103
1,945

* 3,627
52,185

* 103
1,945

* 3,626
18,587

*0
* 513

*0
*7

*0
1,945

*0
60,664

Grantmaking-operating foundations

$100,000 under $1,000,000

950

62,751

950

36,003

781

228

950

419,446

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

764
117

531,229
1,188,653

764
117

270,938
1,043,099

555
76

610
388

764
117

2,116,187
1,742,476
1,741,350

$25,000,000 under $50,000,000

56

675,672

56

534,790

39

1,018

56

$50,000,000 under $100,000,000

37

514,564

37

411,661

26

693

37

2,475,129

$100,000,000 or more

45

993,854

45

172,680

33

3,786

45

21,189,530

Footnotes at end of table.

137

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (book value)
Total investment assets
(book value) [2]
Type of foundation, asset size

Total

Government obligations

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(24)

(25)

(26)

(27)

(28)

(29)

All foundations
Total

78,338

505,143,148

58,242

302,869,455

14,301

Zero or unreported

0

0

0

0

0

34,968,228
0

$1 under $100,000

15,633

762,788

7,104

339,649

939

16,094

$100,000 under $1,000,000

32,418

12,835,872

24,572

8,568,837

4,857

511,817

$1,000,000 under $10,000,000

24,123

65,542,781

21,012

46,318,095

6,066

3,300,542

$10,000,000 under $25,000,000

3,388

44,577,484

3,047

30,430,199

1,301

2,792,858

$25,000,000 under $50,000,000

1,333

38,858,275

1,185

25,321,379

526

2,285,019

$50,000,000 under $100,000,000

738

44,243,876

670

27,909,515

312

2,849,801

$100,000,000 or more

704

298,322,074

652

163,981,781

300

23,212,096

33,863,313

Nonoperating foundations
Total

72,884

475,327,155

55,643

289,526,789

13,530

Zero or unreported

0

0

0

0

0

0

$1 under $100,000

13,483

714,791

6,386

314,595

734

10,194

$100,000 under $1,000,000

30,958

12,344,908

23,973

8,395,098

4,711

492,503

$1,000,000 under $10,000,000

22,759

62,928,240

20,082

44,926,128

5,798

3,183,485

$10,000,000 under $25,000,000

3,138

42,356,954

2,872

29,189,913

1,224

2,636,712

$25,000,000 under $50,000,000

1,228

36,991,338

1,109

24,299,339

495

2,216,999

$50,000,000 under $100,000,000

680

41,495,178

624

26,524,800

291

2,736,599

$100,000,000 or more

638

278,495,746

596

155,876,916

277

22,586,822

1,104,914

Operating foundations
Total

5,454

29,815,993

2,600

13,342,665

771

Zero or unreported

*0

*0

*0

*0

*0

*0

$1 under $100,000

2,150

47,996

* 718

* 25,054

* 205

* 5,900

$100,000 under $1,000,000

1,460

490,963

599

173,739

* 146

* 19,314

$1,000,000 under $10,000,000

1,365

2,614,541

930

1,391,967

268

117,058

$10,000,000 under $25,000,000

250

2,220,529

175

1,240,286

77

156,145

$25,000,000 under $50,000,000

105

1,866,937

76

1,022,040

31

68,020

$50,000,000 under $100,000,000

58

2,748,698

46

1,384,715

21

113,202

$100,000,000 or more

66

19,826,329

56

8,104,864

23

625,274

34,166,127

Grantmaking foundations
Total

69,792

492,041,213

54,599

295,940,776

13,606

Zero or unreported

0

0

0

0

0

0

$1 under $100,000

11,913

585,358

5,921

300,153

832

10,773

$100,000 under $1,000,000

29,373

11,864,212

23,171

8,120,873

4,590

472,815

$1,000,000 under $10,000,000

22,679

63,098,378

20,188

44,871,765

5,843

3,130,781

$10,000,000 under $25,000,000

3,188

42,746,033

2,907

29,407,106

1,236

2,637,171

$25,000,000 under $50,000,000

1,254

37,278,637

1,132

24,445,633

505

2,223,031

$50,000,000 under $100,000,000

709

42,895,320

651

27,357,924

306

2,808,248

$100,000,000 or more

676

293,573,276

629

161,437,323

293

22,883,308

Footnotes at end of table.

138

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (book value)
Total investment assets
(book value) [2]
Type of foundation, asset size

Total

Government obligations

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(24)

(25)

(26)

(27)

(28)

(29)

Grantmaking-nonoperating foundations
Total

66,670

469,445,147

52,918

286,404,544

13,139

Zero or unreported

0

0

0

0

0

33,577,344
0

$1 under $100,000

10,582

556,690

5,409

282,426

730

10,107

$100,000 under $1,000,000

28,576

11,527,364

22,724

7,963,459

4,490

456,270

$1,000,000 under $10,000,000

21,930

61,588,365

19,654

44,126,511

5,654

3,062,267

$10,000,000 under $25,000,000

3,077

41,680,580

2,828

28,822,230

1,209

2,593,150

$25,000,000 under $50,000,000

1,201

36,300,195

1,092

23,929,555

490

2,202,513

$50,000,000 under $100,000,000

672

40,979,289

621

26,392,057

290

2,727,336

$100,000,000 or more

631

276,812,665

590

154,888,306

275

22,525,702

Total

3,123

22,596,065

1,681

9,536,233

466

588,783

Zero or unreported
$1 under $100,000

*0
1,331

*0
28,668

*0
* 513

*0
* 17,727

*0
* 102

*0
* 666

Grantmaking-operating foundations

$100,000 under $1,000,000

797

336,848

447

157,414

* 100

* 16,545

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

749
111

1,510,013
1,065,453

533
79

745,254
584,876

188
27

68,514
44,021

$25,000,000 under $50,000,000

53

978,441

40

516,078

15

20,518

$50,000,000 under $100,000,000

37

1,916,031

30

965,867

16

80,912

$100,000,000 or more

45

16,760,611

39

6,549,017

18

357,606

Footnotes at end of table.

139

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (book value)—continued
Total assets
(fair market value) [2]
Type of foundation, asset size

Corporate stock

Corporate bonds

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(30)

(31)

(32)

(33)

(34)

(35)

All foundations
Total

54,837

222,734,464

27,160

45,166,763

91,380

Zero or unreported

0

0

0

0

0

588,534,809
0

$1 under $100,000

6,170

288,546

1,874

35,008

25,562

764,584

$100,000 under $1,000,000

23,119

6,821,523

10,187

1,235,497

35,077

14,793,296

$1,000,000 under $10,000,000

20,200

35,659,620

11,558

7,357,932

24,520

77,041,243

$10,000,000 under $25,000,000

2,931

22,220,903

1,902

5,416,439

3,429

52,995,438

$25,000,000 under $50,000,000

1,134

18,748,639

750

4,287,721

1,347

46,588,702

$50,000,000 under $100,000,000

653

20,603,100

441

4,456,614

740

51,199,867

$100,000,000 or more

630

118,392,133

447

22,377,551

705

345,151,679

539,711,861

Nonoperating foundations
Total

52,593

212,405,172

26,403

43,258,304

83,622

Zero or unreported

0

0

0

0

0

0

$1 under $100,000

5,554

273,241

1,772

31,160

21,775

668,568

$100,000 under $1,000,000

22,665

6,668,721

10,132

1,233,875

33,110

14,044,990

$1,000,000 under $10,000,000

19,356

34,519,172

11,172

7,223,471

23,021

72,271,792

$10,000,000 under $25,000,000

2,765

21,355,736

1,806

5,197,465

3,158

48,770,669

$25,000,000 under $50,000,000

1,063

17,968,059

702

4,114,281

1,237

42,827,442

$50,000,000 under $100,000,000

608

19,563,834

410

4,224,367

682

47,300,660

$100,000,000 or more

581

112,056,410

409

21,233,685

639

313,827,740

48,822,948

Operating foundations
Total

2,244

10,329,292

756

1,908,459

7,758

Zero or unreported

*0

*0

*0

*0

*0

*0

$1 under $100,000

* 616

* 15,305

* 102

* 3,849

3,787

96,016

$100,000 under $1,000,000

454

152,802

* 55

* 1,623

1,967

748,306

$1,000,000 under $10,000,000

843

1,140,449

386

134,461

1,499

4,769,451

$10,000,000 under $25,000,000

166

865,167

96

218,974

271

4,224,768

$25,000,000 under $50,000,000

71

780,580

48

173,440

110

3,761,260

$50,000,000 under $100,000,000

45

1,039,266

31

232,247

58

3,899,207

$100,000,000 or more

49

6,335,724

38

1,143,866

66

31,323,938

565,569,416

Grantmaking foundations
Total

51,537

217,551,091

26,240

44,223,558

76,492

Zero or unreported

0

0

0

0

0

0

$1 under $100,000

5,095

255,735

1,658

33,645

16,642

561,091

$100,000 under $1,000,000

21,868

6,428,101

9,986

1,219,957

31,156

13,532,369

$1,000,000 under $10,000,000

19,448

34,515,515

11,198

7,225,469

22,838

72,316,669

$10,000,000 under $25,000,000

2,797

21,530,409

1,815

5,239,526

3,207

49,610,398

$25,000,000 under $50,000,000

1,085

18,117,584

719

4,105,018

1,262

43,669,402

$50,000,000 under $100,000,000

634

20,163,821

433

4,385,855

709

49,085,372

$100,000,000 or more

610

116,539,927

431

22,014,088

677

336,794,114

Footnotes at end of table.

140

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (book value)—continued
Total assets
(fair market value) [2]
Type of foundation, asset size

Corporate stock

Corporate bonds

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(30)

(31)

(32)

(33)

(34)

(35)

Grantmaking-nonoperating foundations
Total

50,020

210,042,990

25,777

42,784,210

72,578

Zero or unreported

0

0

0

0

0

530,993,221
0

$1 under $100,000

4,582

242,522

1,556

29,796

14,698

502,634

$100,000 under $1,000,000

21,520

6,287,348

9,984

1,219,841

30,207

13,054,547

$1,000,000 under $10,000,000

18,965

33,937,557

10,949

7,126,688

22,074

70,056,637

$10,000,000 under $25,000,000

2,723

21,094,590

1,781

5,134,490

3,090

47,765,885

$25,000,000 under $50,000,000

1,047

17,705,932

692

4,021,110

1,206

41,772,683

$50,000,000 under $100,000,000

605

19,466,942

409

4,197,779

672

46,523,977

$100,000,000 or more

577

111,308,100

406

21,054,505

632

311,316,859

Total

1,517

7,508,101

463

1,439,349

3,914

34,576,194

Zero or unreported
$1 under $100,000

*0
* 513

*0
* 13,213

*0
* 102

*0
* 3,849

*0
1,945

*0
58,457

Grantmaking-operating foundations

$100,000 under $1,000,000

348

140,753

*2

* 116

950

477,822

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

483
74

577,959
435,818

249
34

98,781
105,036

764
117

2,260,031
1,844,514

$25,000,000 under $50,000,000

38

411,652

27

83,908

56

1,896,720

$50,000,000 under $100,000,000

29

696,880

24

188,076

37

2,561,395

$100,000,000 or more

33

5,231,827

25

959,583

45

25,477,256

Footnotes at end of table.

141

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (fair market value)
Total investment assets
(fair market value) [2]
Type of foundation, asset size

Total

Corporate stock

Government obligations

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(36)

(37)

(38)

(39)

(40)

(41)

(42)

(43)

All foundations
Total

14,301

35,414,535

Zero or unreported

78,338 539,848,926
0

0

58,242 324,672,693
0

0

0

0

54,837 243,423,270
0

0

$1 under $100,000

15,633

571,157

7,104

277,126

939

15,720

6,170

225,587

$100,000 under $1,000,000

32,418

13,082,860

24,572

8,837,374

4,857

528,449

23,119

7,053,107

$1,000,000 under $10,000,000

24,123

69,921,078

21,012

50,072,055

6,066

3,417,177

20,200

39,178,561

$10,000,000 under $25,000,000

3,388

48,355,855

3,047

33,464,300

1,301

2,870,515

2,931

25,044,774

$25,000,000 under $50,000,000

1,333

42,140,586

1,185

27,641,179

526

2,346,927

1,134

20,945,166

$50,000,000 under $100,000,000

738

47,546,736

670

30,231,451

312

2,908,591

653

22,783,044

$100,000,000 or more

704 318,230,653

652 174,149,208

300

23,327,156

630 128,193,032

72,884 503,177,905

55,643 311,034,653

52,593 232,763,330

Nonoperating foundations
Total

13,530

34,306,568

Zero or unreported

0

0

0

0

0

0

0

0

$1 under $100,000

13,483

525,066

6,386

253,711

734

9,820

5,554

212,125

$100,000 under $1,000,000

30,958

12,577,173

23,973

8,661,883

4,711

510,156

22,665

6,897,534

$1,000,000 under $10,000,000

22,759

67,215,955

20,082

48,695,474

5,798

3,299,672

19,356

38,055,153

$10,000,000 under $25,000,000

3,138

45,953,285

2,872

32,135,526

1,224

2,711,707

2,765

24,092,672

$25,000,000 under $50,000,000

1,228

40,115,458

1,109

26,576,793

495

2,281,586

1,063

20,119,456

$50,000,000 under $100,000,000

680

44,648,243

624

28,759,531

291

2,794,401

608

21,661,059

$100,000,000 or more

638 292,142,725

596 165,951,735

277

22,699,226

581 121,725,331

Operating foundations
Total

5,454

36,671,021

2,600

13,638,041

771

1,107,967

2,244

Zero or unreported

*0

*0

*0

*0

*0

*0

*0

10,659,941
*0

$1 under $100,000

2,150

46,091

* 718

* 23,415

* 205

* 5,899

* 616

* 13,463

$100,000 under $1,000,000

1,460

505,687

599

175,491

* 146

* 18,293

454

155,573

$1,000,000 under $10,000,000

1,365

2,705,123

930

1,376,581

268

117,505

843

1,123,407

$10,000,000 under $25,000,000

250

2,402,570

175

1,328,774

77

158,808

166

952,101

$25,000,000 under $50,000,000

105

2,025,128

76

1,064,386

31

65,341

71

825,710

$50,000,000 under $100,000,000

58

2,898,493

46

1,471,920

21

114,191

45

1,121,985

$100,000,000 or more

66

26,087,928

56

8,197,473

23

627,930

49

6,467,701

54,599 317,213,992

Grantmaking foundations
Total

13,606

34,612,780

Zero or unreported

0

0

0

0

0

0

0

0

$1 under $100,000

11,913

449,539

5,921

234,471

832

10,398

5,095

189,570

51,537 237,718,177

$100,000 under $1,000,000

29,373

12,221,986

23,171

8,474,909

4,590

489,407

21,868

6,745,009

$1,000,000 under $10,000,000

22,679

67,415,487

20,188

48,606,466

5,843

3,247,141

19,448

38,016,849

$10,000,000 under $25,000,000

3,188

46,324,817

2,907

32,370,860

1,236

2,712,263

2,797

24,288,278

$25,000,000 under $50,000,000

1,254

40,459,533

1,132

26,677,499

505

2,287,347

1,085

20,223,603

$50,000,000 under $100,000,000

709

46,029,935

651

29,579,084

306

2,866,582

634

22,243,616

$100,000,000 or more

676 311,200,342

629 171,270,704

293

22,999,643

610 126,011,251

Footnotes at end of table.

142

69,792 524,101,640

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in securities (fair market value)
Total investment assets
(fair market value) [2]
Type of foundation, asset size

Total

Government obligations

Corporate stock

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(36)

(37)

(38)

(39)

(40)

(41)

(42)

(43)

Grantmaking-nonoperating foundations
Total

13,139

34,019,666

Zero or unreported

66,670 496,986,039
0

0

52,918 307,570,448
0

0

0

0

50,020 230,061,886
0

0

$1 under $100,000

10,582

423,077

5,409

218,684

730

9,732

4,582

178,501

$100,000 under $1,000,000

28,576

11,869,528

22,724

8,314,857

4,490

473,921

21,520

6,600,561

$1,000,000 under $10,000,000

21,930

65,821,253

19,654

47,856,213

5,654

3,178,416

18,965

37,435,474

$10,000,000 under $25,000,000

3,077

45,219,156

2,828

31,742,060

1,209

2,667,957

2,723

23,805,734

$25,000,000 under $50,000,000

1,201

39,382,619

1,092

26,138,330

490

2,266,377

1,047

19,790,097

$50,000,000 under $100,000,000

672

44,103,472

621

28,626,788

290

2,785,138

605

21,564,166

$100,000,000 or more

631 290,166,935

590 164,673,516

275

22,638,125

577 120,687,353

Grantmaking-operating foundations
Total

3,123

27,115,600

1,681

9,643,544

466

593,114

1,517

7,656,291

Zero or unreported
$1 under $100,000

*0
1,331

*0
26,461

*0
* 513

*0
* 15,787

*0
* 102

*0
* 665

*0
* 513

*0
* 11,069

$100,000 under $1,000,000

797

352,458

447

160,052

* 100

* 15,486

348

144,448

$1,000,000 under $10,000,000
$10,000,000 under $25,000,000

749
111

1,594,234
1,105,662

533
79

750,252
628,800

188
27

68,725
44,306

483
74

581,375
482,544

$25,000,000 under $50,000,000

53

1,076,915

40

539,169

15

20,970

38

433,507

$50,000,000 under $100,000,000

37

1,926,464

30

952,295

16

81,443

29

679,450

$100,000,000 or more

45

21,033,407

39

6,597,188

18

361,518

33

5,323,899

Footnotes at end of table.

143

Domestic Private Foundations and Related Excise Taxes, Tax Year 2009
Statistics of Income Bulletin | Winter 2013

Table 1. Domestic Private Foundations: Number and Selected Financial Data, by Type of Foundation
and Size of End-of-year Fair Market Value of Total Assets, Tax Year 2009—Continued
[All figures are estimates based on a sample—money amounts are in thousands of dollars]

Investments in
securities (fair market
value)—continued
Type of foundation, asset size

Net worth
(book value)

Noncharitable-use
assets

Minimum investment
return

Corporate bonds
Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

Number
of returns

Amount

(44)

(45)

(46)

(47)

(48)

(49)

(50)

(51)

All foundations
Total

27,160

45,834,888

Zero or unreported

0

0

91,535 523,341,455
* 207

* -529

91,615 492,264,460
519

25,485

91,055
519

24,514,730
1,274

$1 under $100,000

1,874

35,819

25,562

645,705

25,357

781,076

24,844

38,995

$100,000 under $1,000,000

10,187

1,255,818

35,030

14,261,887

35,025

13,249,643

34,977

659,638

$1,000,000 under $10,000,000

11,558

7,476,317

24,519

70,771,883

24,500

67,406,591

24,500

3,357,463

$10,000,000 under $25,000,000

1,902

5,549,011

3,425

47,744,363

3,427

45,754,464

3,427

2,279,806

$25,000,000 under $50,000,000

750

4,349,086

1,347

41,590,800

1,343

39,368,982

1,343

1,959,502

$50,000,000 under $100,000,000

441

4,539,816

740

46,111,445

740

44,184,304

740

2,203,258

$100,000,000 or more

447

22,629,020

705 302,215,901

705 281,493,915

705

14,014,794

83,778 486,689,393

83,778 467,187,950

83,319

23,262,146

Nonoperating foundations
Total

26,403

43,964,755

Zero or unreported

0

0

* 207

* -529

416

25,385

416

1,269

$1 under $100,000

1,772

31,766

21,775

552,629

21,570

722,155

21,159

36,049

$100,000 under $1,000,000

10,132

1,254,193

33,063

13,630,744

33,058

12,725,482

33,010

633,430

$1,000,000 under $10,000,000

11,172

7,340,649

23,021

66,691,452

23,021

64,904,260

23,021

3,233,483

$10,000,000 under $25,000,000

1,806

5,331,146

3,155

44,231,430

3,157

43,636,022

3,157

2,173,884

$25,000,000 under $50,000,000

702

4,175,751

1,237

38,670,917

1,235

37,742,226

1,235

1,878,166

$50,000,000 under $100,000,000

410

4,304,072

682

42,743,480

682

41,873,789

682

2,087,835

$100,000,000 or more

409

21,527,178

639 280,169,270

639 265,558,631

639

13,218,030

Total

756

1,870,133

7,756

36,652,062

7,838

25,076,510

7,735

1,252,584

Zero or unreported

*0

*0

*0

*0

* 102

* 101

* 102

*5

$1 under $100,000

* 102

* 4,053

3,787

93,077

3,787

58,921

3,685

2,946

$100,000 under $1,000,000

* 55

* 1,625

1,967

631,143

1,967

524,160

1,967

26,208

$1,000,000 under $10,000,000

386

135,668

1,498

4,080,431

1,479

2,502,332

1,479

123,980

$10,000,000 under $25,000,000

96

217,865

270

3,512,933

270

2,118,442

270

105,922

$25,000,000 under $50,000,000

48

173,335

110

2,919,882

108

1,626,756

108

81,336

$50,000,000 under $100,000,000

31

235,744

58

3,367,965

58

2,310,515

58

115,423

$100,000,000 or more

38

1,101,843

66

22,046,631

66

15,935,283

66

796,764

76,901 481,637,139

Operating foundations

Grantmaking foundations
Total

26,240

44,883,035

76,696

24,015,595

Zero or unreported

0

0

* 205

* -529

* 413

* 25,379

* 413

* 1,269

$1 under $100,000

1,658

34,503

16,642

423,942

16,642

629,318

16,438

31,466

$100,000 under $1,000,000

9,986

1,240,493

31,109

12,971,547

31,156

12,344,944

31,155

615,799

$1,000,000 under $10,000,000

11,198

7,342,475

22,838

66,855,938

22,838

65,071,586

22,838

3,249,434

$10,000,000 under $25,000,000

1,815

5,370,319

3,203

45,029,266

3,206

44,073,504

3,206

2,199,026

$25,000,000 under $50,000,000

719

4,166,549

1,262

39,398,805

1,259

38,111,560

1,259

1,898,842

$50,000,000 under $100,000,000

433

4,468,886

709

44,618,009

[Text truncated at 120,000 characters. The full text is on the page linked above.]

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A655c926fd6aefd7e. Public record. Not legal advice.