# Domestic Private Foundations and Charitable Trusts: Tax > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A83975808c89ffc8f ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 by Cynthia Belmonte P rivate foundations distribute billions of dollars to the charitable sector each year. Generally, these distributions are grants to other taxexempt organizations to assist in funding their charitable programs. Because the activities of private foundations are primarily charitable, most income that they receive is exempt from tax under Internal Revenue Code (IRC) section 501(c)(3). However, private foundations are subject to a variety of IRS regulations regarding their activities. Private foundations report compliance with IRS regulations, as well as detailed financial information, using the annual information return Form 990-PF, Return of Private Foundation (or Section 4947(a)(1) Charitable Trust Treated as a Private Foundation). Certain nonexempt charitable trusts that are treated as private foundations for tax purposes are also required to file this return.1 Form 990-PF can provide insight into a wide range of issues related to private foundations and nonexempt charitable trusts, such as organizational and operating characteristics; composition of assets, revenue, and expenditures; and the relationship between charitable contributions and investment return. The total number of Forms 990-PF filed by private foundations increased by 3 percent to 79,535 between Tax Years 2004 and 2005, and increased another 3 percent to 81,850 between Tax Years 2005 and 2006. The number of returns filed by nonexempt charitable trusts increased by 3 percent to 3,612 between Tax Years 2004 and 2005, but decreased by 3 percent to 3,502 between Tax Years 2005 and 2006. Contributions, gifts, and grants distributed to the charitable sector by private foundations increased substantially for Tax Years 2005 and 2006. Private foundations distributed 15 percent more in contributions, gifts, and grants for Tax Year 2005 than for the previous year. Contributions, gifts, and grants distributed for Tax Year 2006 increased another 10 percent over Tax Year 2005. Nonexempt charitable Cynthia Belmonte is an economist with the Special Studies Special Projects Section. This data release was prepared under the direction of Melissa R. Ludlum, Chief. 262 trusts distributed 4 percent more in contributions, gifts, and grants for Tax Year 2005 than for the previous year, but, for Tax Year 2006, the amount of contributions, gifts, and grants paid decreased 7 percent. Selected financial data reported on Forms 990-PF by private foundations and nonexempt charitable trusts for Tax Years 2004 through 2006, including asset, revenue, and expense items, are shown in Figure A.2 Often, investment assets provide the basis for giving by grantmaking foundations and charitable trusts. The value of investment assets held by private foundations increased by 7 percent between Tax Years 2004 and 2005, and increased by 18 percent between Tax Years 2005 and 2006. For each year, investment assets represented more than 94 percent of the fair market value of total assets reported by private foundations, which also increased by 7 percent to $545.9 billion for 2005, and 18 percent to $645.8 billion for 2006. The value of investment assets held by nonexempt charitable trusts increased by 4 percent between Tax Year 2004 and Tax Year 2005, and by 5 percent between Tax Year 2005 and Tax Year 2006. Nonexempt charitable trusts reported an aggregate fair market value of total assets of $5.8 billion for Tax Year 2005 and $6.1 billion for Tax Year 2006; for both years, investment assets represented nearly 98 percent of the total. Revenue received by private foundations and nonexempt charitable trusts for Tax Years 2005 and 2006 consisted primarily of income derived from assets and contributions, gifts, and grants received. Income derived from assets, including net gains from sales of assets, interest and dividends from securities, and interest on savings, accounted for more than half of total revenue reported by private foundations for Tax Years 2005 and 2006. Contributions, gifts, and grants received represented an additional 40 percent of total revenue. Overall, private foundations reported 30 percent more revenue for Tax Year 2005 than for Tax Year 2004, and 23 percent more revenue for Tax Year 2006 than for Tax Year 2005. Total revenue reported by nonexempt charitable trusts increased by 15 percent to $579 million between Tax Year 2004 and Tax Year 2005, and increased 6 percent to $611 million between Tax Year 2005 and Tax 1 These trusts, defined under section 4947(a)(1), have only charitable beneficiaries and pay taxes using Form 1041, U.S. Income Tax Return for Estates and Trusts. However, they may be able to avoid all tax by deducting charitable expenses; thus, they are subject to the private foundation rules. 2 For complete information on Forms 990-PF filed for Tax Year 2004, see Ludlum, Melissa, “Domestic Private Foundations and Charitable Trusts: Charitable Distributions and Investment Assets, Tax Year 2004,” Statistics of Income Bulletin, Fall 2007, Volume 27, Number 2. Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure A Domestic Private Foundations and Charitable Trusts: Selected Financial Items and Percentage Changes, Tax Years 2004-2006 [All figures are estimates based on samples—money amounts are in millions of dollars] Private foundations Item Number of returns Total assets (fair market value) Cash (non-interest bearing accounts) Investments, total Savings and temporary cash investments Investments in securities, total Government obligations Corporate stock Corporate bonds Other investments [1] Total revenue Contributions, gifts, and grants received Net gain (less loss) from sales of assets Dividends and interest from securities Interest on savings Net investment income Total expenses Disbursements for charitable purposes Contributions, gifts, and grants paid Excise tax on net investment income 2004 2005 2006 (1) (2) (3) 76,897 509,924 4,718 481,177 30,449 361,158 37,859 279,921 43,378 89,570 58,668 23,531 21,070 8,815 1,836 34,019 36,552 32,125 27,625 469 79,535 545,938 5,168 515,795 33,836 373,084 37,401 294,779 40,903 108,875 76,365 31,224 29,036 9,863 2,230 44,269 42,822 37,017 31,856 624 81,850 645,810 6,678 609,661 42,304 403,668 38,718 325,759 39,191 163,689 94,107 39,576 35,747 11,401 2,672 54,200 48,797 40,686 34,932 796 Charitable trusts Percentage change, 2004-2005 (4) Percentage change, 2005-2006 (5) Percentage change, 2004-2005 (9) 3.4 7.1 9.5 7.2 11.1 3.3 -1.2 5.3 -5.7 21.6 30.2 32.7 37.8 11.9 21.5 30.1 17.2 15.2 15.3 33.0 2.9 18.3 29.2 18.2 25.0 8.2 3.5 10.5 -4.2 50.3 23.2 26.7 23.1 15.6 19.8 22.4 14.0 9.9 9.7 27.6 Number of returns Total assets (fair market value) Cash (non-interest bearing accounts) Investments, total Savings and temporary cash investments Investments in securities, total Government obligations Corporate stock Corporate bonds Other investments [1] 3,511 5,579 42 5,457 289 4,289 406 3,285 599 879 3,612 5,832 40 5,699 319 4,591 480 3,521 589 789 3,502 6,142 43 6,005 321 4,874 474 3,801 598 810 2.9 4.5 -4.8 4.4 10.4 7.0 18.2 7.2 -1.7 -10.2 Percentage change, 2005-2006 (10) -3.0 5.3 7.5 5.4 0.6 6.2 -1.3 8.0 1.5 2.7 Total revenue Contributions, gifts, and grants received Net gain (less loss) from sales of assets Dividends and interest from securities Interest on savings Net investment income Total expenses Disbursements for charitable purposes Contributions, gifts, and grants paid Excise tax on net investment income 502 169 159 130 8 304 369 332 314 5 579 163 230 143 10 383 389 345 325 6 611 109 285 162 13 456 367 322 302 7 15.3 -3.6 44.7 10.0 25.0 26.0 5.4 3.9 3.5 20.0 5.5 -33.1 23.9 13.3 30.0 19.1 -5.7 -6.7 -7.1 16.7 Item 2004 2005 (6) 2006 (7) (8) [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. Year 2006. For Tax Year 2005, more than two-thirds of revenue reported by nonexempt charitable trusts were received from net gains from sales of assets, interest and dividends from securities, and interest on savings; while for Tax Year 2006, these sources accounted for 75 percent of total revenue. Contributions, gifts, and grants received accounted for 28 percent of revenue reported by nonexempt charitable trusts for Tax Year 2005 and only 18 percent of revenue reported for Tax Year 2006. 263 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 The Statistics of Income Study The Statistics of Income (SOI) Division conducts an annual study of private foundations, based on information returns filed with the Internal Revenue Service. The SOI data are estimates based on a sample of Forms 990-PF selected to represent the entire filing population for a given tax year. The data presented in this article are from a sample of Forms 990PF filed for Tax Years 2005 and 2006 by domestic private foundations, and from the population of Tax Years 2005 and 2006 Forms 990-PF filed by domestic nonexempt charitable trusts that were treated as private foundations. Domestic foundations and trusts are those that were organized in the United States. Tax Year 2005 includes all accounting periods beginning in Calendar Year 2005 and thus ending between December 2005 and November 2006. Tax Year 2006 includes all accounting periods beginning in Calendar Year 2006 and thus ending between December 2006 and November 2007. Statistics of Income studies based on stratified random samples of returns filed by private foundations have been conducted for Tax Years 1974, 1979, 1982, 1983, and annually since 1985. Studies based on sampled Forms 990-PF filed by charitable trusts have been conducted for Tax Year 1979 and annually since 1989. Beginning with Tax Year 2003, the population of Forms 990-PF filed by nonexempt charitable trusts has been included in the SOI study. Composition of Filers Under IRC section 501(c)(3), private foundations and other organizations that conduct activities or provide financial support for charitable purposes are granted exemption from the income taxes described in IRC, Title 26, Subtitle A.3 Foundations represent a minority of tax-exempt organizations; most tax-exempt organizations are hospitals, schools, churches, and organizations that receive broad support from the general public. Many of these types of tax-exempt organizations file Form 990, Return of Organization Exempt From Income Tax, or Form 990-EZ, the short version of this information return.4 Several characteristics distinguish a foundation from other types of tax-exempt organizations, including its narrow sphere of support and control. A private foundation may be organized as a corporation, association, or Programs termed “charitable” refer to tax-exempt activities that are charitable, educational, scientific, social, literary, or religious in nature. For an indepth discussion of organizations other than private foundations that are tax-exempt under IRC section 501(c)(3), see Arnsberger, Paul, “Charities, Business Leagues, and Other Tax-Exempt Organizations, 2006,” Statistics of Income Bulletin, in this issue. 3 264 trust. Typically, a foundation is funded by a small number of private donors. Additionally, control of the private foundation is generally limited to an individual, family, or corporation. Nonexempt charitable trusts that are treated as private foundations for tax purposes are trusts that have not obtained tax-exempt status, but they are funded and operated nearly identically to tax-exempt private foundations. These trusts have exclusively charitable interests and have amounts in trust for which donors are allowed to claim a tax deduction for charitable contributions. Unlike private foundations, nonexempt charitable trusts are required to pay an annual tax on income that is not distributed for charitable purposes, and they must report such income and tax on Form 1041, U.S. Fiduciary Income Tax Return, in addition to filing Form 990-PF. Nonexempt charitable trusts with no taxable income for a tax year may file Form 990-PF only. All private foundations and nonexempt charitable trusts are classified as one of two operating types— “nonoperating” or “operating.” Private foundations and nonexempt charitable trusts that are characterized as nonoperating primarily contribute grants and other financial support to charitable organizations or activities; they generally do not operate their own charitable progams. Nonoperating private foundations and charitable trusts are by far the most common Form 990-PF filers; for each of Tax Years 2005 and 2006, over 90 percent of Forms 990-PF filed were filed by nonoperating foundations or trusts. Private foundations and charitable trusts that principally focus on the operation of their own charitable programs are known as operating foundations. Private foundations that operate as museums, housing or healthcare facilities, or organizations that conduct scientific research are examples of foundations that frequently receive operating status. In order to qualify as operating, a foundation must meet certain financial criteria (see “Operating foundations and charitable trusts” in the Explanation of Selected Terms section for information on operating foundations). Figure B shows the number of returns filed, fair market value of total assets, total revenue, and total contributions, gifts, and grants paid, for Tax Year 2006 reported by Form 990-PF filers, by organization and operating type. More than 95 percent of 4 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure B Domestic Private Foundations and Charitable Trusts: Selected Financial Items, by Size of End-of-Year Fair Market Value of Total Assets, Tax Year 2006 [All figures are estimates based on samples—money amounts are in millions of dollars] Nonoperating foundations All foundations Asset size Number of returns (1) Total FMV assets (2) Total grants (4) Total revenue (3) Number of returns (5) Total FMV assets (6) Private foundations, total 81,850 645,810.2 94,107.2 34,932.2 74,364 Less than $1,000,000 52,730 13,402.1 4,789.2 3,933.5 47,121 12,324.5 $1,000,000 under $50,000,000 27,613 173,142.8 31,226.5 12,251.2 25,848 160,945.6 $50,000,000 or more 1,507 459,265.3 58,091.5 Percentage of total 18,747.5 Total Asset size 1,395 424,438.8 Percentage of total 100.0 100.0 100.0 100.0 100.0 64.4 2.1 5.1 11.3 63.4 2.1 33.7 26.8 1.8 71.1 Nonoperating foundations 33.2 61.7 35.1 34.8 53.7 1.9 Operating foundations 26.9 71.0 Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more 597,708.9 Total revenue (7) Total grants (8) Number of returns (9) Total FMV assets (10) Total revenue (11) 100.0 Total grants (12) Private foundations, total 86,195.6 33,850.2 7,486 48,101.4 7,911.6 Less than $1,000,000 3,566.1 3,840.8 5,610 1,077.6 1,223.1 92.8 $1,000,000 under $50,000,000 28,032.6 11,487.5 1,765 12,197.2 3,193.8 763.7 $50,000,000 or more 54,596.9 18,521.9 Percentage of total 112 34,826.6 3,494.6 Percentage of total 225.6 Total 1,082.0 100.0 100.0 100.0 100.0 100.0 100.0 Less than $1,000,000 4.1 11.3 74.9 2.2 15.5 8.6 $1,000,000 under $50,000,000 $50,000,000 or more 32.5 63.3 23.6 1.5 25.4 72.4 Asset size Number of returns (1) 33.9 54.7 All charitable trusts Total FMV assets (2) Total grants (4) Total revenue (3) 40.4 70.6 44.2 20.9 Nonoperating charitable trusts Number of returns (5) Total FMV assets (6) Nonexempt charitable trusts, total 3,502 6,141.6 611.1 302.0 3,469 Less than $1,000,000 2,548 747.0 99.2 58.4 2,521 739.7 $1,000,000 under $10,000,000 860 2,445.5 247.2 107.3 855 2,425.6 $10,000,000 or more 94 2,949.1 264.6 Percentage of total 136.3 Total Asset size 93 2,932.1 Percentage of total 100.0 100.0 100.0 100.0 100.0 72.8 12.2 16.2 19.3 72.7 12.1 24.6 39.8 2.7 48.0 Nonoperating charitable trusts 40.5 43.3 35.5 24.6 45.1 2.7 Operating charitable trusts 39.8 48.1 Less than $1,000,000 $1,000,000 under $10,000,000 $10,000,000 or more 6,097.4 Total revenue (7) Total grants (8) Number of returns (9) Total FMV assets (10) Total revenue (11) 100.0 Total grants (12) Nonexempt charitable trusts, total 606.0 301.2 33 44.2 5.1 0.8 Less than $1,000,000 98.7 58.2 27 7.3 0.5 0.2 $1,000,000 under $10,000,000 243.2 106.9 5 19.9 4.0 0.4 264.1 136.2 Percentage of total 1 0.5 0.2 100.0 $10,000,000 or more Total 17.0 Percentage of total 100.0 100.0 100.0 100.0 100.0 Less than $1,000,000 16.3 19.3 81.8 16.5 9.8 25.0 $1,000,000 under $10,000,000 40.1 35.5 15.2 45.0 78.4 50.0 $10,000,000 or more 43.6 45.2 3.0 38.5 9.8 25.0 NOTES: Detail may not add to totals because of rounding and processing tolerances. "FMV" is an abbreviation for fair market value. 265 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Tax Year 2006 Forms 990-PF were filed by private foundations. In terms of financial activity, private foundations were even more dominant, reporting 99 percent of the fair market value of total assets held, total revenue, and total contributions, gifts, and grants distributed by all Form 990-PF filers. For this reason, the remainder of the article will focus solely on private foundations. The attached tables, however, include data for nonexempt charitable trusts. Most foundations were similarly sized, with the majority of foundations holding assets with fair market values of less than $1,000,000. The median fair market value of total assets held by foundations for Tax Year 2006 was $521,035. However, the mean fair market value of total assets held by private foundations for Tax Year 2006 was $7.9 million, illustrating the presence of a small number of foundations holding large amounts of assets. Large private foundations, defined as those with $50 million or more in fair market value of total assets at the end of Tax Year 2006, accounted for the majority of financial activity. These organizations represented less than 2 percent of private foundations for Tax Year 2006, yet held 71 percent of the aggregate fair market value of total assets reported. Further, less than 1 percent of private foundations— those with assets valued at $100 million or more— held over 63 percent of all assets. Large foundations also received most of the revenue, 62 percent, and distributed more than half, 54 percent, of grants reported by all private foundations for Tax Year 2006. Ten Largest Domestic Foundations The largest foundations, based on asset size, and the largest grantmakers, based on the total amount of contributions, gifts, and grants reported for Tax Year 2006, are shown in Figure C.5 Data obtained from Forms 990-PF differ from most other IRS return data, in that individual return information may be published. In fact, returns are available for public review under IRC section 6104(b). For Tax Year 266 2006, ten foundations alone held one-fifth of the total assets reported by the domestic Form 990-PF filers. With assets valued at $33.0 billion, the Bill and Melinda Gates Foundation Trust was by far the largest organization in the domestic top ten. The Bill and Melinda Gates Foundation, with $29.7 billion in assets, was the second-largest domestic private foundation.6 For Tax Year 2006, the J. Paul Getty Trust was the only operating foundation included in the top ten largest organizations. This foundation, which operates the J. Paul Getty Museum, reported assets valued at more than four times those reported by the second-largest operating foundation, the Washingtonbased Casey Family Programs, which ranked as the 23rd-largest foundation. The Bill and Melinda Gates and Ford foundations were the leading grantmakers in Tax Year 2006, distributing $1.6 billion and $0.6 billion in contributions, gifts, and grants for the year, respectively. Investment Assets and Income Investment performance significantly impacts the ability of private foundations to fund their short- and long-term grantmaking. Private foundations, particularly those that focus on long-term grantmaking, rely on growth from investment assets to finance future charitable distributions. Income derived from investment assets, including sales, dividends, and interest, provided more than half of all revenue reported by foundations for Tax Years 2005 and 2006. Figure D shows inflation-adjusted changes in the values of total and selected types of investments held by nonoperating foundations, between Tax Years 2004 and 2006.7 The real value of investments increased by only 4 percent from Tax Year 2004 to Tax Year 2005, but increased much more dramatically, by 15 percent, from Tax Year 2005 to Tax Year 2006. Securities, comprising corporate stocks and bonds and government obligations, represented the largest component of investment, accounting for 72 percent of total investments for Tax Year 2005 and 66 percent for Tax 5 Seven of the ten largest foundations and seven of the ten biggest grantmakers had calendar year accounting periods, meaning that all of their activity occurred during the calendar year period. However, three of the ten had other fiscal year accounting periods. For Tax Year 2006, the Ford Foundation had an accounting period ending in September 2007, the J. Paul Getty Trust in June 2007, and the W.K. Kellogg Foundation and the W.K. Kellogg Foundation Trust in August 2007; therefore, much of their activity for Tax Year 2006 occurred in Calendar Year 2007. See the Data Sources and Limitations section. 6 In October, 2006, the Bill and Melinda Gates Foundation Trust was created to manage the endowment assets of the Bill and Melinda Gates Foundation (“the foundation”), which distributes money to grantees. The grants paid reported by the Bill and Melinda Gates Foundation Trust were combined with the amount reported by the Bill and Melinda Gates Foundation to represent the total grantmaking efforts of the foundation throughout the tax year. 7 Data for investment assets in the text and in Figure D differ from those presented elsewhere in this article because they have been adjusted for inflation. Tax Year 2004 and 2005 investment totals were adjusted based on the 2000 chain-type price index for Gross Domestic Product as reported by the U.S. Department of Commerce, Bureau of Economic Analysis; 2006 was used as the base year. Unless otherwise noted, all other data are in current dollars. Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure C Top Ten Domestic Private Foundations, by Size of End-of-Year Fair Market Value of Total Assets and Charitable Grants Paid, Tax Year 2006 [Money amounts are in millions of dollars] Ten Largest Organizations State Name and ranking (1) 1. Bill and Melinda Gates Foundation Trust [1] 2. Bill and Melinda Gates Foundation [1] 3. The Ford Foundation 4. The J. Paul Getty Trust [2] 5. The Robert Wood Johnson Foundation 1 6. The William & Flora Hewlett Foundation 7. W.K. Kellogg Foundation [3] 8. Lilly Endowment Inc. 9. The David and Lucile Packard Foundation 10. John D. and Catherine T. Macarthur Foundation Total WA WA NY CA NJ CA MI IN CA IL Ten Biggest Grantmakers State Name and ranking (1) 1. Bill and Melinda Gates Foundation [1] 2. The Ford Foundation 3. Lilly Endowment Inc. 4. The Robert Wood Johnson Foundation 5. Glaxosmithkline Patient Access Programs Foundation 6. W.K. Kellogg Foundation [3] 7. The Annenberg Foundation 8. The David and Lucile Packard Foundation 9. Gordon E. and Betty I. Moore Foundation 10. John D. and Catherine T. Macarthur Foundation Total WA NY IN NJ PA MI PA CA CA IL Total grants paid (3) Total FMV assets (2) 33,030 29,655 13,799 11,187 10,103 8,516 8,420 7,602 6,354 6,178 134,844 Total grants paid (2) 1,552 617 352 331 324 303 280 238 231 217 4,445 Total FMV assets (3) 0 1,552 617 12 331 212 303 352 238 217 3,834 29,655 13,799 7,602 10,103 27 8,420 2,685 6,354 5,836 6,178 90,659 [1] In October, 2006, the Bill and Melinda Gates Foundation Trust was created to manage the endowment assets of the Bill and Melinda Gates Foundation (“the foundation”), which distributes money to grantees. The grants paid reported by the Bill and Melinda Gates Foundation Trust were combined with the amount reported by the the Bill and Melinda Gates Foundation to represent the total grantmaking efforts of the foundation throughout the tax year. [2] The J. Paul Getty Trust is an operating foundation. All other organizations listed are nonoperating foundations. [3] The W.K. Kellogg Foundation Trust (classified as a private foundation and not as a section 4947(a)(1) charitable trust) is located in New York and has a "pass-through" relationship with the W.K. Kellogg Foundation, located in Michigan. Typically, the entire amount of the annual qualifying (charitable) distributions of the W. K. Kellogg Foundation Trust is made in the form of a grant to the W.K. Kellogg Foundation, which then redistributes the grant for charitable purposes. The combined total assets of the two organizations i i are shown h in i the h "Total "T l FMV assets"" column, l but, b in i order d to avoid id duplication, d li i only l the h grants paid id by b the h W.K. WK K Kellogg ll F Foundation d i are shown h iin the h "T "Totall grants paid" column. NOTES: Detail may not add to totals due to rounding. "FMV" is an abbreviation for fair market value. Year 2006. Savings and temporary cash investments represented 7 percent of total investments for Tax Years 2005 and 2006; while “other investments” represented 21 and 27 percent of total investments, respectively, for Tax Years 2005 and 2006. The “other investments” category represents an aggregation of several items, including investments in land, buildings, and equipment (less accumulated depreciation); mortgage loans; and additional items such as advances, certificates of investment, and investments in art, gold, coins, and gems. The value of fixed-income investments, including government obligations and corporate bonds, held by private foundations each declined, in real terms, by 4 percent and 9 percent, respectively, for Tax Year 2005. Holdings of government obligations were unchanged for Tax Year 2006, while holdings of corporate bonds declined another 7 percent, in real terms. However, increases in the respective values of savings and temporary cash investments, corporate stocks, and other investments more than offset the decreases in the values of fixed income investments for both Tax Years 2005 and 2006. In real terms, the value of investments held by medium foundations, defined as those holding from $1 million to $50 million in fair market value of total 267 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure D Domestic Private Foundations: Investments and Percentage Changes, by Size of End-of-Year Fair Market Value of Total Assets, in Constant Dollars, Tax Years 2004-2006 [All figures are estimates based on samples—money amounts are in millions of dollars] Asset size All foundations Item Investments, total (fair market value) Savings and temporary cash investments Investments in securities, total Government obligations Corporate stock Corporate bonds Other investments [1] 2004 2005 2006 (1) 512,935 32,459 384,995 40,358 298,396 46,241 95,482 (2) 532,300 34,918 385,023 38,598 304,212 42,212 112,359 (3) 609,661 42,304 403,668 38,718 325,759 39,191 163,689 Less than $1,000,000 Percentage Percentage change, change, 2004-2005 2005-2006 (4) 3.8 7.6 0.0 -4.4 1.9 -8.7 17.7 (5) 14.5 21.2 4.8 0.3 7.1 -7.2 45.7 2004 2005 2006 (6) 12,198 2,344 8,083 605 6,419 1,059 1,771 (7) 11,955 2,333 8,133 619 6,458 1,057 1,488 (8) 11,768 2,342 7,871 628 6,197 1,046 1,555 $1,000,000 under $50,000,000 Item Investments, total (fair market value) Savings and temporary cash investments Investments in securities, total Government obligations Corporate stock Corporate bonds Other investments [1] 2004 2005 2006 (11) 147,861 13,838 113,108 12,268 86,582 14,258 20,915 (12) 152,282 14,653 114,813 11,939 89,650 13,224 22,815 (13) 160,833 16,364 118,801 11,658 93,952 13,191 25,668 3.0 5.9 1.5 -2.7 3.5 -7.3 9.1 (9) -2.0 -0.5 0.6 2.3 0.6 -0.2 -16.0 (10) -1.6 0.4 -3.2 1.5 -4.0 -1.0 4.5 $50,000,000 or more Percentage Percentage change, change, 2004-2005 2005-2006 (14) Percentage Percentage change, change, 2004-2005 2005-2006 (15) 5.6 11.7 3.5 -2.4 4.8 -0.2 12.5 2004 2005 2006 (16) 352,877 16,277 263,804 27,485 205,395 30,924 72,796 (17) 368,063 17,932 262,076 26,040 208,104 27,931 88,056 (18) 437,059 23,598 276,995 26,431 225,610 24,953 136,466 Percentage Percentage change, change, 2004-2005 2005-2006 (19) 4.3 10.2 -0.7 -5.3 1.3 -9.7 21.0 (20) 18.7 31.6 5.7 1.5 8.4 -10.7 55.0 [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. NOTES: Amounts have been adjusted for inflation based on the 2000 chain-type price index for Gross Domestic Product, as published by the U.S. Department of Commerce, Bureau of Economic Analysis and may differ from investment amounts in other figures and tables. Tax Year 2006 is the base year. Detail may not add to totals because of rounding and processing tolerances. assets, increased by 3 percent from Tax Years 2004 to 2005, and by 6 percent from Tax Years 2005 to 2006. The value of investments held by large foundations, those with $50 million or more in fair market value of total assets, rose by 4 percent from Tax Years 2004 to 2005, and by 19 percent from Tax Years 2005 to 2006. Total asset values of small foundations, those with less than $1 million in fair market value of total assets, declined 2 percent from Tax Years 2004 to 2005, and declined by the same amount for Tax Year 2006. The “net investment income yield” and “rate of total return” are indicators of the annual investment performance of private foundations and charitable trusts. Net investment income measures the realized investment income received from investment assets. It includes interest, dividends, net income from real- 268 ized capital gains, and other income earned independently of a foundation’s charitable purpose. The net investment income yield equals net investment income divided by the value of noncharitable-use assets.8 The real rate of total return on assets provides a more comprehensive indication of total investment performance than the net investment income yield. It includes the realized income from investments and other assets, as well as the unrealized appreciation or depreciation in computing the fair market value of assets. The rate, which is an indicator of 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.9 8 The net investment income amount used in calculating the net investment income yield was obtained from column (b) of the income statement, found in Part I of Form 990-PF. 9 The rate-of-total-return formula used here is the same as that developed and used by Salamon and Voytek in their studies on foundation assets. See Salamon, Lester M. and Kenneth P. Voytek (1989), Managing Foundation Assets: An Analysis of Foundation Investment and Payout Procedures and Performance, The Council on Foundations, Washington, DC, p. 32. The formula for this calculation is shown in Appendix A at the end of the article. Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 For Tax Year 2006, larger-sized nonoperating foundations generally realized higher net investment income yields, and experienced significantly higher rates of total return than for the previous tax year. The median net investment income yield for large nonoperating foundations for Tax Year 2006 was 8.0 percent, compared to a median 7.2 percent in Tax Year 2005. Rates of total return for large nonoperating foundations also increased, from 1.7 percent for Tax Year 2005 to 9.8 percent for Tax Year 2006. Figure E shows median and mean net investment income yields and rates of total return on assets for domestic nonoperating foundations, by size, for Tax Years 2005 and 2006. The median rates, which minimize the effects of large outliers in the data, provide an approximate measure of the investment performance of a typical foundation. For all nonoperating foundations, the median net investment income yield realized for Tax Year 2005 was higher than the Tax Year 2004 net investment income yield, and similarly were higher in Tax Year 2006 than in Tax Year 2005, indicating that foundations received larger rates of income from their investment assets in each subsequent year. In contrast, the median rate of total return fell from 3.5 percent for Tax Year 2004 to -0.9 percent for Tax Year 2005, continuing the downward trend from the prior year. The median rate of total return increased significantly from Tax Year 2005 to Tax Year 2006, to 6.5 percent. Net investment income yields and rates of total return generally increased with organization size. Median rates of return for medium foundations dropped from 5.0 percent for Tax Year 2004 to -0.3 percent for Tax Year 2005. For Tax Year 2006, the median rate of total return for small foundations was 4.1 percent, up from -1.6 percent for the previous year. Nevertheless, median rates of total return were higher for medium and large nonoperating foundations than for small nonoperating foundations. Excise Tax on Net Investment Income The realized income from investments, or net investment income, that is reported by private foundations and nonexempt charitable trusts is subject to an excise tax each year under IRC section 4940. This tax is intended to cover expenses incurred by the Internal Revenue Service in the oversight of foundation activities and the enforcement of laws governing their exempt status. Generally, domestic foundations are taxed at a rate equal to 2 percent of their worldwide net investment incomes.10 Domestic private foundations that were able to demonstrate growth in the rate of their charitable distributions were eligible to pay the net investment income tax at a reduced 1-percent rate. Specifically, if total Tax Year 2006 qualifying distributions were larger than the total of averaged qualifying distributions made between 2001 and 2005 plus 1 percent of the total amount of current net Figure E Domestic Nonoperating Private Foundations: Net Investment Income Yields and Rates of Total Return on Assets, by Size of Beginning-of-Year Fair Market Value of Total Assets, Tax Years 2005 and 2006 [All figures are estimates based on samples] 2005 Asset size All nonoperating private foundations Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more 2006 Rates of total return (percentages) Net investment income yields (percentages) Rates of total return (percentages) Mean Median Mean Median Mean Median Mean (2) 10.4 11.4 8.7 11.9 (3) -0.9 -1.6 -0.3 1.7 (4) 2.1 2.2 1.8 4.7 (5) 5.2 4.7 6.0 8.0 (6) 17.7 15.8 21.1 11.1 (7) 6.5 4.1 8.1 9.8 (8) 9.0 8.5 9.5 13.2 Net investment income yields (percentages) Median (1) 4.3 3.6 5.2 7.2 Foreign foundations, which are organized abroad but required to file Form 990-PF and pay excise taxes on net investment income, are subject to a 4-percent tax on the value of their U.S.-based net investment incomes. Data from returns filed by foreign foundations are not included in this article. 10 269 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure F Domestic Private Foundations Reporting Excise Tax on Investment Income, by Size of End-of-Year Fair Market Value of Total Assets, in Constant Dollars, Tax Years 2005 and 2006 [All figures are estimates based on samples--money amounts are in millions of dollars] Year and asset size 2005 All Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more 2006 All Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more Number of returns (1) 63,519 37,611 24,629 1,279 65,583 37,575 26,553 1,455 Percentage Net investment income (NII) of all [1] organizations (2) 79.9 71.6 95.9 95.9 80.1 71.3 96.2 96.5 (3) 44,138 920 11,744 31,474 52,110 1,134 14,027 36,950 Qualifying distributions (4) 36,219 2,903 12,912 20,403 38,935 3,523 13,384 22,027 Percentage of organizations Excise tax on reporting: net investment income 1-percent tax 2-percent tax (5) (6) 644 14 175 456 796 16 215 566 (7) 44.7 42.8 47.2 51.0 44.4 44.6 43.8 48.4 55.3 57.2 52.8 49.0 55.6 55.4 56.2 51.6 [1] Represents net investment income of foundations and charitable trusts reporting excise tax. For Tax Year 2006, total net investment income was $54.2 billion for all foundations. and $455.7 million for all charitable trusts. NOTES: Amounts have been adjusted for inflation based on the 2000 chain-type price index for Gross Domestic Product, as published by the U.S. Department of Commerce, Bureau of Economic Analysis. Tax Year 2006 is the base year. Detail may not add to totals due to rounding. investment income, a foundation was eligible for the reduced tax rate for Tax Year 2006. In addition, certain domestic operating foundations may receive a total exemption from this excise tax. To qualify for the total exemption, operating foundations must show a broader sphere of support and control than other private foundations by maintaining public support through income and contributions received from a broad section of the general public for a 10-year period. Additionally, they must have boards of trustees or other governing bodies that are representative of the general public, rather than boards composed of a small group of “insiders.” Boards of trustees can consist of no more than 25 percent “disqualified persons” for the tax year, none of whom can serve as an officer of the foundation. 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. For each of Tax Years 2005 and 2006, only 17 percent of all operating foundations reported that they had met the exemption requirements and were exempt from the excise tax on net investment ­income.11 270 11 Foundations reported $44.3 billion in net investment income for Tax Year 2005, of which $44.1 billion were subject to the excise tax, which totaled $644 million. For Tax Year 2006, foundations reported $54.2 billion in net investment income, $52.1 billion of which were subject to the excise tax, which totaled $796 million. Figure F shows selected information for private foundations that reported excise tax on net investment income for Tax Years 2005 and 2006. For each of Tax Years 2005 and 2006, 44 percent of foundations reported eligibility for the reduced 1-percent rate. Generally, large foundations were more likely to qualify for the reduced tax rate than smaller foundations; for example, for Tax Year 2006, 48 percent of large foundations were eligible for the reduction, compared to 45 percent of small foundations. Despite the lower average tax rates, excise tax on net investment income paid by large foundations accounted for 71 percent of total tax liability for each of Tax Years 2005 and 2006. The Private Foundation Rules The Tax Reform Act of 1969 (TRA69) established rules specific to private foundations and formed the basis for sections 4940-4945 of the IRC. Section 4940 describes the excise tax on “net investment in- The J. Paul Getty Trust, the largest operating foundation, is exempt from the excise tax on net investment income. Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 come,” described in the previous section of this article. Under section 4942, nonoperating private foundations, and nonexempt charitable trusts treated as private foundations, are required to distribute a minimum annual amount for charitable purposes, known as the “distributable amount,” or pay an excise tax on any undistributed portion. The distributable amount equals approximately 5-percent of the fair market value of a private foundation’s investment assets. The remaining private foundation rules detail excise taxes on a variety of “prohibited activities” that are considered to be contrary to the public interest. Private foundations and nonexempt charitable trusts report taxes on the activities described in IRC sections 4941-4945 on Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code. Legislation included in the Pension Protection Act of 2006 increased the excise taxes rate imposed on private foundations for taxable years beginning after August 17, 2006. Specifically, for the failure to distribute income (as described under section 4942), the initial tax rate on nonoperating private foundations was increased from 15 percent of the undistributed amount to 30 percent of the undistributed amount. The other excise tax rates for “prohibited activities,” as described in IRC sections 4941-4945, were also doubled. Qualifying Distributions The required distributable amount, as described under section 4942, is derived from a foundation’s minimum investment return, which is calculated based on the reported value of its net investment, or “noncharitable-use,” assets. Noncharitable-use assets are those assets held for investment purposes only and may include such items as securities, investments in art, coins, or other collectables, and investments in real estate. Conversely, assets used directly to conduct charitable activities, such as office buildings, art held by museums, and computers are considered “charitable-use” assets and are excluded from the minimum investment return calculation. Valuation methods used for assets included in the minimum investment return calculation are described under net value of noncharitable-use assets in the Explanation of Terms section. The minimum investment return is calculated as 5 percent of the net value of noncharitable-use assets, which equals the value of noncharitable-use assets, less both the indebtedness incurred to acquire these assets and the amount of cash held for charitable activities. Cash deemed held for charitable activities is generally 1.5 percent of noncharitable-use assets less acquisition indebtedness. Finally, the distributable amount is the minimum investment return reduced by the excise tax on net investment income and any income taxes paid plus or minus other adjustments. Additional adjustments are detailed under Net adjustments to distributable amount in the Explanation of Terms section. Under section 4942, foundations that fail to meet this distributable amount by the close of a 1-year grace period are subject to an excise tax equaling 15 percent of the undistributed amount.12 Current-year distributions for charitable purposes that may be directed toward meeting the distribution requirement are known as “qualifying distributions.” Qualifying distributions are primarily the contributions, gifts, and grants disbursed by a foundation or charitable trust throughout the year. However, qualifying distributions may also include operating and administrative expenses related to conducting charitable operations; “set-asides,” which are amounts earmarked for future charitable distributions; program-related investments, such as loans to other 501(c)(3) organizations; and amounts paid to acquire buildings, equipment, supplies, or other assets for charitable use. For Tax Year 2006, contributions, gifts, and grants comprised 82 percent of total qualifying distributions, followed by operating and administrative expenses, at 13 percent. Amounts paid to acquire assets for charitable-use represented 3 percent of total qualifying distributions; and program-related investments and set-asides, combined, accounted for less than 2 percent of the total. Figure G shows qualifying distributions and required distributable amounts for nonoperating private foundations, by end-of-year asset size, for Tax Year 2006. Qualifying distributions for nonoperating foundations totaled $37.6 billion, an amount more than 1.5 times larger than the aggregated required distributable amount for 2006. As a result of legislation included in the Pension Protection Act of 2006, some of the private foundations included in the statistics—i.e., foundations with taxable years beginning after August 17, 2006—were subject to the higher 30-percent tax rate. 12 271 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure G Domestic Nonoperating Private Foundations: Qualifying Distributions and Distributable Amounts, by Size of End-of-Year Fair Market Value of Total Assets, Tax Year 2006 Billions of dollars $38 $37.6 $36 $34 $32 $30 $28 $26 $24.8 $24 $22 $20 $17.7 $18 $15.0 $16 $14 $12 $10 $8 $7.0 $5.4 $6 $4 $1.8 $2 $0.1 $0 All foundations, total Less than $100,000 $4.1 $2.9 $2.3 $0.6 $100,000 under $1,000,000 under $1,000,000 $10,000,000 $10,000,000 under $50,000,000 $3.5 $2.1 $50,000,000 under $100,000,000 $100,000,000 or more Asset size Qualifying distributions Distributable amount NOTE: Detail may not add to totals because of rounding and processing tolerances. 272 While large private foundations provided the majority of qualifying distributions to charitable organizations, smaller-sized foundations were more likely to make distributions in excess of the required amount. Small foundations, those that held less than $1,000,000 in fair market value of total assets, distributed amounts more than 6 times larger than required. Some small foundations serve as “passthrough” organizations for larger foundations. These small foundations distribute grants that they receive from the larger foundations and may thus report qualifying distributions that are large relative to their asset size. As aggregate asset size increased for pri- vate foundations, the percentage by which qualifying distributions exceeded the distribution requirement decreased. This may indicate the preference of larger-sized foundations to focus on long-term, rather than short-term, giving, by maintaining a more substantial portion of their asset bases for future grantmaking. Excess Distributions and Undistributed Income By law, nonoperating foundations and charitable trusts must meet the distributable amount requirement for the current tax year by the end of the next Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 tax year or pay the section 4942 excise tax on the undistributed amount. For example, a foundation must have disbursed the required amount for Tax Year 2006 before the end of Tax Year 2007 in order to avoid paying the excise tax. The distributable amount is calculated at the end of the tax year, and, because it is based on averaged net investment asset values, could be influenced by late-year changes. For example, if net investment asset growth is higher than expected in the closing months of a tax year, a foundation or charitable trust may be unable to sufficiently increase its contributions to meet the requirement. Foundations and charitable trusts that have not met the requirement may choose to take advantage of the 1-year tax-free “grace period” and report all or any unmet portion of the current-year required distributable amount as “undistributed income” on the current-year Form 990-PF. If any portion of this undistributed income is not paid by the end of the subsequent tax year, it becomes taxable. Thus, a nonoperating organization could direct all or part of its 2006 qualifying distributions toward the 2005 required distributable amount. Similarly, foundations and charitable trusts also carry forward excess qualifying distributions and may apply them to unmet distributable amount requirements for up to 5 subsequent tax years. In other words, a foundation that did not meet the distributable amount requirement for Tax Year 2006, but had distributions in excess of the required distributable amount for any of Tax Years 2001 through 2005, could have applied those distributions to the distributable amount for Tax Year 2006. The majority of foundations used current-year qualifying distributions to satisfy the current-year distributable amount requirement and thus did not take advantage of the 1-year grace period. For each of Tax Years 2005 and 2006, about 35 percent of foundations that had a minimum distribution requirement reported undistributed income at the end of the tax year. Small foundations, whose net investment values are perhaps more predictable than those of their larger counterparts, were the least likely to require the additional tax year to meet the distribution requirement. For example, only 30 percent of small foundations carried Tax Year 2006 undistributed income to Tax Year 2007, compared to 43 percent of medium and 44 percent of large foundations. For both Tax Years 2005 and 2006, nonoperating foundations reported that 69 percent of the aggregate current-year distributable amount was satisfied based on current-year qualifying distributions. Figure H provides a breakout of the current-year distributable amount for nonoperating private foundations, showing the percentage of the distributable amount that was met by current-year qualifying distributions and excess qualifying distributions from previous tax years, as well as unpaid amounts carried forward as undistributed income to the following tax year. For each of Tax Years 2005 and 2006, large foundations directed over 70 percent of current-year qualifying distributions to the distributable amount. For each of Tax Years 2005 and 2006, about 5 percent of the current-year distribution requirement for all nonoperating foundations was fulfilled using carryovers from a previous tax year. The percentage of the distributable amount met using carryovers decreased with asset size, with small foundations reporting that 7 percent of their Tax Year 2006 distributable amounts were satisfied using carryovers from previous years. In contrast, large foundations paid just 5 percent of the Tax Year 2006 distributable amount using previous-year carryovers. Payout Rates The payout rate captures the relationship between an organization’s charitable distributions and its investment assets and provides insight into the degree to which nonoperating foundations and charitable trusts exceed their charitable payout requirements. Current-year distributions, along with carryovers, are adjusted to include certain taxes and deductions and divided by the total value of noncharitable-use assets to arrive at an organization’s payout rate.13 Tax Year 2005 and 2006 median payout rates for private foundations, by asset size, are shown in Figure I. The figure also shows ranges of payout rates and the associated percentage of foundations whose payout rates fell within each range. The median payout rate for private foundations remained fairly stable from Tax Year 2004 (5.4 percent) to Tax Year 2006 (5.6 percent), while investment assets of nonoperating foundations grew by 7 The payout rate was calculated by dividing the amount of (adjusted) qualifying distributions by the value of noncharitable-use assets. The numerator is adjusted to account for deductions and additions made in the distributable amount calculation. The payout formula is shown in Appendix A at the end of the article. 13 273 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure H Domestic Nonoperating Private Foundations, Distributions Applied to Distributable Amount, and Undistributed Income Carried Over, as a Percentage of Distributable Amount, by Size of End-of-Year Fair Market Value of Total Assets, Tax Years 2005 and 2006 Tax Year 2005 Asset size 23.5 $50,000,000 or more 4.8 71.7 30.6 $1,000,000 under $50,000,000 5.4 Less than $1,000,000 5.7 All nonoperating foundations 5.0 64.0 25.5 68.8 25.7 69.3 0 20 40 60 80 100 Percentage Tax Year 2005Distributions undistributed income Domestic Nonoperating Private Foundations, Applied to Distributable Amount, Previous distributions applied to Tax Year 2005 Amount, and Undistributed Income Carried Over, asexcess a Percentage of Distributable Current-year qualifying distributions applied to 2005 distributable amount by Size of End-of-Year Fair Market Value of Total Assets, Tax Years 2005 and 2006—Continued Tax Year 2006 Asset size 23.8 $50,000,000 or more 5.2 $1,000,000 under $50,000,000 5.7 70.9 30.1 Less than $1,000,000 64.2 22.2 7.0 All nonoperating foundations 70.8 25.6 5.4 0 69.0 20 40 60 80 100 Percentage Tax Year 2006 undistributed income Previous excess distributions applied to Tax Year 2006 Current-year qualifying distributions applied to 2006 distributable amount 274 percent from Tax Year 2004 to Tax Year 2005, and by 19 percent from Tax Year 2005 to Tax Year 2006. Similar to Tax Year 2004, most nonoperating private foundations, 69 percent, met or exceeded the 5-percent payout requirement for each of Tax Years 2005 and 2006. More than a third of nonoperating private foundations—approximately 36 percent (in Tax Year 2005) and 38 percent (in Tax Year 2006)—reported payout rates that were between 4.8 percent and 6.5 percent. One-quarter of private foundations reported payout rates of 13 percent or more. Approximately 10 percent of nonoperating foundations reported payout rates of less than 3.3 percent, with 5 percent of nonoperating private foundations reporting payout rates of less than 0.2 percent for Tax Year 2005 (and slightly less, 4 percent, for Tax Year 2006). Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Figure I Domestic Nonoperating Private Foundations: Median Payout Rates and Selected Percentages, by Size of End-of-Year Fair Market Value of Total Assets, Tax Years 2004-2006 All foundations Item Less than $1,000,000 2004 2005 2006 2004 2005 2006 (1) (2) (3) (4) (5) (6) Median payout rate (percentage) 5.4 5.6 5.6 5.8 6.2 6.3 100.0 4.9 5.4 13.8 11.0 24.4 15.3 15.0 5.1 5.0 100.0 4.7 5.7 10.9 9.8 26.2 15.0 15.8 5.1 6.8 100.0 3.7 6.1 10.6 10.5 27.2 16.7 15.3 5.2 4.7 100.0 6.7 5.6 11.4 10.5 20.4 13.7 17.5 6.8 7.4 100.0 6.3 5.5 8.2 8.7 22.4 13.1 18.6 7.0 10.1 100.0 4.7 6.2 7.0 9.5 23.8 15.7 18.2 7.6 7.2 Percentage of foundations reporting payout rates equaling: Total Less than 0.2 percent 0.2 percent under 3.3 percent 3.3 percent under 4.8 percent 4.8 percent under 5.0 percent 5.0 percent under 6.5 percent 6.5 percent under 13.0 percent 13.0 percent under 75.0 percent 75.0 percent under 200.0 percent 200.0 percent or more Item Median payout rate (percentage) $1,000,000 under $50,000,000 $50,000,000 or more 2004 2005 2006 2004 2005 2006 (7) (8) (9) (10) (11) (12) 5.2 5.2 5.2 5.1 5.2 5.2 100.0 1.6 5.2 18.3 12.0 31.5 18.4 10.5 1.8 0.6 100.0 1.8 6.3 15.8 11.8 32.9 18.5 10.7 1.5 0.9 100.0 2.2 6.1 16.2 12.3 32.3 18.4 10.7 1.2 0.6 100.0 0.4 3.3 21.4 11.8 39.1 15.2 8.0 0.4 0.4 100.0 0.6 2.5 18.0 13.3 38.7 16.6 9.1 1.1 0.2 100.0 0.7 3.7 20.1 11.2 37.2 17.7 8.4 0.4 0.5 Percentage of foundations reporting payout rates equaling: Total Less than 0.2 percent 0.2 percent under 3.3 percent 3.3 percent under 4.8 percent 4.8 percent under 5.0 percent 5.0 percent under 6.5 percent 6.5 percent under 13.0 percent 13.0 percent under 75.0 percent 75.0 percent under 200.0 percent 200.0 percent or more Small nonoperating private foundations exceeded the payout requirement far more frequently than did medium or large foundations, while large foundations were more likely to have payout rates at or near the required 5 percent. Almost half (49 percent) of small nonoperating foundations reported payout rates of 6.5 percent or higher for each of Tax Years 2005 and 2006. Additionally, for Tax Year 2006, 15 percent of small foundations reported payout rates of 75 percent or higher, compared to 2 percent of medium foundations, and only 1 percent of large foundations. Small foundations that served as passthrough organizations for Tax Year 2006 were likely to have made charitable distributions that exceeded their asset values, resulting in notably high payout rates. For large nonoperating foundations, the median payout rate was 5.2 percent, and nearly half (48 percent) of large foundations reported payout rates that were be- tween 4.8 percent and 6.5 percent for Tax Year 2006. Of nonoperating foundations in the three asset-size classes, large foundations were the least likely to report payout rates that were lower than 3.3 percent or higher than 13 percent. Summary There was a 3-percent annual increase in the number of private foundations that filed Form 990-PF between Tax Years 2004 and 2006. The number of nonexempt charitable trusts treated as private foundations that filed the return increased by 3 percent from Tax Year 2004 to Tax Year 2005, but returned to 2004 levels the following year. Nonoperating private foundations, which provide grants to other charitable organizations, accounted for the majority of Form 990-PF filers and their financial activity. The newly organized Bill and Melinda Gates Foundation Trust 275 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 276 was the largest foundation, based on asset size, while the Bill and Melinda Gates Foundation remained the biggest grantmaker, based on contributions, gifts, and grants disbursed, for Tax Year 2006. Investment assets, the basis for computing the required distributable amount, are frequently the cornerstone for giving by grantmaking foundations and charitable trusts. The value of these investments increased by 4 percent for private foundations and only 1 percent for nonexempt charitable trusts, in real terms, between Tax Years 2004 and 2005. Between Tax Years 2005 and 2006, the value of these investments increased by 15 percent for private foundations and only 2 percent for nonexempt charitable trusts, in real terms. In current dollars, investment assets totaled $515.8 billion for private foundations and $5.7 billion for nonexempt charitable trusts in Tax Year 2005, and $609.7 billion for private foundations and $6.0 billion for nonexempt charitable trusts in Tax Year 2006. The aggregate amount of net investment income received increased by 22 percent for private foundations and 19 percent for nonexempt charitable trusts from Tax Year 2005 to Tax Year 2006. The excise tax on this income, imposed under IRC section 4940, was $796 million for private foundations and $7 million for nonexempt charitable trusts. Net investment income yields and rates of total return for private foundations suggested that foundations received higher rates of realized income from investment assets for both Tax Years 2005 and 2006, but experienced a significant decline in unrealized investment growth for Tax Year 2005 and an increase for Tax Year 2006. Both net investment income yields and rates of total return were highest for large private foundations. Overall, qualifying distributions, which included contributions, gifts, and grants and other outlays for charitable purposes, exceeded the required 2006 distributable amount for nonoperating private foundations. Qualifying distributions totaled $37.6 billion for Tax Year 2006 for nonoperating private foundations; $33.9 billion of that amount consisted of contributions, gifts, and grants distributed. The majority of the distributable amount was satisfied based on current-year qualifying distributions for foundations. Median payout rates, which measure the relationship between charitable distributions and investment assets, were around the required 5 percent for nonoperating private foundations. Generally, private foun- dations reported higher payout rates than nonexempt charitable trusts. Large private foundations deviated less from the required 5-percent payout rate than did smaller foundations. Small foundations were more likely than their larger counterparts to distribute at rates of 13 percent or more. However, small foundations also distributed at rates of 3.3 percent or less, well below the required amount, more frequently than larger-sized foundations. Data Sources and Limitations The statistics presented in this article are based on two distinct samples of Forms 990-PF that were filed with the Internal Revenue Service for Tax Years 2005 and 2006. Organizations having accounting periods beginning in 2005 (and therefore ending between December 2005 and November 2006) that filed returns in Calendar Years 2006 and 2007 that posted to the IRS Business Master File during those years were included in the Tax Year 2005 sample. Likewise, organizations having accounting periods beginning in 2006 (and therefore ending between December 2006 and November 2007) that filed returns in Calendar Years 2007 and 2008 that posted to the IRS Business Master File during those years were included in the Tax Year 2006 sample. Some part-year returns were also included in the samples for organizations that changed their accounting periods, or filed initial or final returns. In each sample, approximately 69 percent of the domestic private foundations had accounting periods covering a calendar-year period or, in some cases, part-year periods that ended in ­December. Each 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) nonexempt charitable trust). All returns filed by nonexempt charitable trusts were selected for inclusion in the study. The private foundation sample was designed to provide reliable estimates of total assets and total revenue. To accomplish this, 100 percent of returns filed for foundations with fair market asset value of $10 million or more were included in the samples, since these organizations represented the vast majority of financial activity. For each of Tax Years 2005 and 2006, approximately 7 percent of all foundations reported $10 million or more in fair market value of total assets and 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 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 For Tax Year 2005, there were 8,244 foundation returns in the sample selected from a population of 83,137. The population of charitable trusts selected for Tax Year 2005 was 3,759. For Tax Year 2006, there were 9,112 foundation returns in the sample selected from a population of 85,257. The population of charitable trusts selected for Tax Year 2006 was 3,629. The difference between the actual population of Form 990-PF records that posted to the IRS Business Master File during the designated sampling periods and the estimated population of Forms 990-PF 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 IRS counts of the actual population of Form 990-PF filed, but were rejected from the SOI estimates. 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 or audit procedures were not captured in the statistics. Changes made based on taxpayer amendment were captured, if available. 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 estimates can be percent, depending on asset size. The realized sampling rates for the Tax Year 2005 and 2006 studies, classified by asset-size category, are included in Figure J. Figure K shows the magnitude of sampling error, measured by coefficients of variation, for selected items from the Tax Year 2005 and 2006 studies. 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. Figure J Realized Sampling Rates for Private Foundation Returns, Tax Years 2005 and 2006 End-of-year fair market value of total assets Realized sampling rate (percentage) 2005 2006 Less than $125,000 1.0 1.0 $125,000 under $400,000 1.9 1.9 $400,000 under $1,000,000 2.0 2.0 $1 million under $2.5 million 6.2 6.7 $2.5 million under $10 million 10.1 9.9 $10 million or more 100.0 100.0 Figure K Coefficients of Variation for Domestic Private Foundations, Selected Items, by Size of End-of-Year Fair Market Value of Total Assets, Tax Years 2005 and 2006 2005 2006 Asset-size class Asset-size class Item Number of returns Fair market value of total assets Total investments, fair market value Total revenue Net investment income Total expenses Contributions, gifts, and grants paid Qualifying distributions Distributable amount All foundations Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more [1] All foundations Less than $1,000,000 $1,000,000 under $50,000,000 $50,000,000 or more [1] (1) 0.68 0.31 0.33 1.46 0.55 1.93 1.91 2.03 0.36 (2) 1.07 1.48 1.95 12.76 8.37 16.27 16.54 17.36 4.06 (3) 0.63 1.06 1.16 3.52 2.03 3.10 3.29 3.05 1.18 (4) n/a n/a n/a n/a n/a n/a n/a n/a n/a (5) 0.63 0.11 0.12 0.97 0.47 2.46 2.83 2.73 0.29 (6) 0.04 1.51 2.00 15.98 9.76 20.74 24.18 22.11 9.02 (7) 0.08 0.37 0.44 1.58 1.63 1.99 2.14 2.12 0.57 (8) n/a n/a n/a n/a n/a n/a n/a n/a n/a [1] Returns in this category are sampled at a 100-percent rate and are not subject to sampling error. 277 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 found in SOI Sampling Methodology and Data Limitations, later in this issue. Explanation of Terms 278 The following explanations describe terms as they applied to private foundations: Charitable trust—A charitable trust, also referred to as a “nonexempt” charitable trust, is defined in Internal Revenue Code section 4947(a)(1) as an organization (1) that is not considered tax‑exempt under section 501(a); (2) that has exclusively charitable interests; and (3) that has amounts in trust for which donors are allowed to claim a tax deduction for charitable contributions. Nonexempt charitable trusts that are not publicly supported are subject to the excise tax provisions that apply to private foundations and are required to file Form 990‑PF. (“Publicly supported” nonexempt charitable trusts are required to file Form 990, Return of Organization Exempt From Income Tax.) Nonexempt charitable trusts that are treated as private foundations must pay an annual tax on income (usually from investments) that is not distributed for charitable purposes, and they must report such income and tax on Form 1041, U.S. Fiduciary Income Tax Return. 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. Typically, they represent the largest component of “qualifying distributions.” 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 follows the tax year for which the return was filed. For example, foundations were required to distribute their Tax Year 2006 amounts before the end of Tax Year 2007. Failure to distribute income within this period results in an excise tax on the undistributed portion. As a result of legislation included in the Pension Protection Act of 2006, the excise tax was increased from 15 percent to 30 percent of the undistributed amount for taxable years beginning after August 17, 2006. 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 990‑PF, 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 amounts. 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, capital gain net income, rents, payments with respect to securities loans (as defined in Code section 512(a)(5)), and royalties 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 which 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 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 are 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 noncharitableuse 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 endof-year value for all assets held by the foundation. Nonoperating foundations and charitable trusts—These are organizations 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 2006, 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 2006 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. An organization’s status as a nonoperating foundation was indicated on Form 990-PF, Part VII, line 9. Operating foundations and charitable trusts— These organizations generally expended their in- comes for direct, active involvement in a tax‑exempt activity, such as operating a library or museum, or conducting scientific research. Operating foundations were exempted from the income distribution requirement and related excise taxes that were applicable to their nonoperating counterparts. To qualify as an operating foundation, the organization had to meet both an “income test” and one of three other tests: an “assets test,” an “endowment test,” or a “support test.” 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 (as opposed to the payout of grants in support of such programs). Adjusted net income represented the amount of income from charitable functions, investment activities, setasides, 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 directly use 65 percent or more of its assets for the active conduct of charitable activities. To meet the endowment test, a foundation had to regularly 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 had to regularly 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. 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). While most operating foundations paid the excise tax on net investment income, some operating foundations were exempt from this tax under section 4940(d)(2) of the Internal Revenue Code. In order to be exempt from the Tax Year 2006 excise tax on net investment income, an operating foundation was re279 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 quired to (1) maintain public support for a minimum of 10 taxable years; (2) maintain a governing body at all times that is broadly representative of the general public and that is comprised of no more than 25-percent disqualified individuals; and (3) at no time during the year include a disqualified individual as an officer of the foundation. An organization’s status as an operating foundation was indicated on Form 990PF, Part VII, line 9. Private foundation—A private foundation is defined in Internal Revenue Code 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 Code 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 section 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 280 first set-aside 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 IR Code section 4942(g) (2)(B)(ii), a foundation must attach a distribution schedule to its annual return for the year of the setaside 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—Total assets are 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) beginning‑of‑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 distribution 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 990‑PF, 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 2006 “distributable amount” by the end of Tax Year 2007 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. Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 Appendix A Rate of Total Return = [Ending Fair Market Value of Assets ‑ Indexed Beginning Fair Market Value of Assets ‑ Contributions Received + Grants Paid + Operating and Administrative Expenses + Excise Tax Paid on Net Investment Income] DIVIDED BY -----------------------------------------------[Indexed Beginning Fair Market Value of Assets + 50 percent of Contributions Received] To calculate the rate of total return shown in Figure E, samples of private foundation information returns for 2 consecutive years were matched in order to analyze both the beginning and end-of-year fair market value data. The beginning fair market value of assets for 2006 equals the ending fair market value reported on the 2005 tax return. Thus, in order to provide a consistent form of measurement by which to compare rates of total return among different years, the ending fair market value of asset amounts (reported for both the year subject to the computation and the prior year) was used to compute the rate of return. In order to obtain an inflation-adjusted real rate of return, the beginning-of-year fair market value of assets was indexed based on the 2000 chain-type price index for Gross Domestic Product as published by the Bureau of Economic Analysis, using 2006 as the base year. To maximize comparability between the real rate of total return and the net investment income yield formulas, the published net investment income yields for Tax Year 2006 also exclude organizations for which returns were not sampled for both Tax Years 2005 and 2006. Similarly, the published net investment income yields for Tax Year 2005 also exclude organizations for which returns were not sampled for both Tax Years 2004 and 2005. Payout Rate = Qualifying Distributions (Part XII, line 4) + Taxes (Part XI, line 2c) – Recoveries of Amounts Treated as Qualifying Distributions (Part XI, line 4) + Deduction from Distributable Amount (Part XI, line 6) + Excess Distributions Applied to 2005 (Part XIII, column A, line 5) DIVIDED BY -----------------------------------------------Net Value of Noncharitable-Use Assets (Part X, line 5) NOTE: Additional data for private foundations and charitable trusts (including data tables for Tax Year 2005 and prior years) can be found on the SOI Web site at www.irs.gov/taxstats. (Click on “Private Foundations.”) 281 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006 [All figures are estimates based on a sample—money amounts are in thousands dollars] Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Footnotes at end of table. 282 Number of returns Total revenue Selected sources of revenue Contributions, gifts, and grants received Number Amount of returns Dividends and interest from securities Number Amount of returns Number of returns Amount (1) (2) (3) 81,850 2,535 20,722 29,473 22,782 3,463 1,368 742 765 79,606 1,731 19,342 29,419 22,782 3,460 1,366 741 765 94,107,195 267,729 1,275,527 3,245,987 13,352,600 9,550,273 8,323,585 8,105,541 49,985,953 36,410 942 10,564 12,630 9,424 1,530 613 346 360 39,575,942 427,928 1,171,569 1,994,906 7,460,581 4,849,812 4,305,934 3,659,361 15,705,852 59,788 * 691 8,483 23,591 21,003 3,284 1,295 703 738 11,400,961 * 6,603 16,880 295,138 1,584,988 1,170,147 1,066,776 1,061,145 6,199,285 74,364 2,437 17,072 27,612 21,375 3,208 1,265 685 710 72,221 1,633 15,790 27,558 21,375 3,207 1,263 684 710 86,195,645 264,019 512,549 2,789,552 12,184,971 8,591,337 7,256,324 7,563,387 47,033,506 31,344 844 8,295 11,372 8,359 1,330 525 302 317 35,250,592 424,218 454,397 1,675,112 6,737,667 4,257,556 3,539,354 3,448,673 14,713,614 56,243 * 691 7,299 22,697 19,913 3,084 1,218 654 686 10,843,984 * 6,603 15,118 282,746 1,516,106 1,116,325 1,028,642 999,901 5,878,544 7,486 * 99 3,650 1,861 1,407 255 103 57 55 7,385 * 99 3,551 1,861 1,407 253 103 57 55 7,911,550 * 3,710 762,978 456,435 1,167,629 958,936 1,067,262 542,154 2,952,447 5,066 * 99 2,269 1,258 1,065 200 88 44 43 4,325,350 * 3,710 717,172 319,794 722,914 592,257 766,579 210,688 992,238 3,546 0 1,184 894 1,089 200 77 49 52 556,977 0 1,763 12,392 68,882 53,822 38,134 61,244 320,742 68,591 1,579 13,719 26,338 20,952 3,261 1,298 703 740 67,700 1,283 13,128 26,338 20,952 3,260 1,296 703 740 87,746,557 265,704 550,254 2,691,106 11,530,460 8,570,185 7,583,735 7,537,185 49,017,927 29,562 * 593 7,210 11,087 8,088 1,371 553 319 341 34,570,127 * 425,960 501,472 1,504,956 5,955,381 4,121,658 3,741,632 3,260,545 15,058,523 54,871 * 691 6,609 22,051 19,746 3,135 1,250 671 718 11,179,896 * 6,603 13,614 282,672 1,532,491 1,134,017 1,044,660 1,020,510 6,145,328 64,468 1,480 11,844 25,091 20,300 3,134 1,246 672 701 63,579 1,184 11,253 25,091 20,300 3,134 1,244 672 701 82,566,720 261,994 466,119 2,527,211 10,834,692 7,978,239 6,869,224 7,224,405 46,404,836 26,701 * 494 5,927 10,290 7,596 1,275 510 295 313 32,142,320 * 422,251 420,011 1,457,250 5,525,350 3,761,846 3,174,597 3,173,216 14,207,799 52,328 * 691 5,621 21,255 19,193 3,030 1,212 644 681 10,760,757 * 6,603 12,329 271,485 1,486,627 1,104,141 1,025,933 983,523 5,870,117 4,123 * 99 1,875 1,247 653 127 52 31 39 4,122 * 99 1,875 1,247 653 126 52 31 39 5,179,837 * 3,710 84,136 163,895 695,768 591,946 714,511 312,779 2,613,091 2,861 * 99 1,283 * 796 492 96 43 24 28 2,427,807 * 3,710 81,461 * 47,706 430,032 359,812 567,035 87,329 850,724 2,542 0 * 987 796 552 105 38 27 37 419,139 0 * 1,285 11,187 45,865 29,877 18,727 36,987 275,212 (4) (5) (6) (7) Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Selected sources of revenue—continued Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Net gain (less loss) from sales of assets Number Amount of returns (8) (9) Total expenses Excess of revenue (less loss) over expenses Net investment income Number of returns Amount Number of returns Amount Number of returns Amount (10) (11) (12) (13) (14) (15) 49,590 * 296 4,942 19,349 19,176 3,154 1,254 687 732 35,746,576 * -179,507 23,588 529,645 3,460,306 2,827,941 2,357,439 2,801,172 23,925,990 79,178 2,027 19,243 29,055 22,541 3,448 1,359 739 765 48,796,817 1,246,336 1,388,316 2,950,836 6,840,521 4,818,086 4,346,579 4,160,764 23,045,378 79,365 1,435 19,539 29,276 22,782 3,460 1,367 741 765 45,310,378 -978,607 -112,789 295,151 6,512,078 4,732,187 3,977,006 3,944,777 26,940,575 69,177 * 843 12,142 27,731 22,197 3,417 1,349 735 763 54,200,020 * 16,191 66,488 1,062,702 5,879,659 4,527,033 3,782,870 4,414,481 34,450,596 47,138 * 296 4,547 18,656 18,192 2,955 1,175 637 681 33,890,773 * -179,507 23,042 521,299 3,306,878 2,705,868 2,270,708 2,611,091 22,631,393 71,892 1,928 15,692 27,293 21,135 3,195 1,256 683 710 43,690,331 1,242,626 656,001 2,470,057 6,037,009 4,136,421 3,648,770 3,861,807 21,637,639 72,178 1,435 16,086 27,415 21,375 3,207 1,265 684 710 42,505,314 -978,607 -143,452 319,494 6,147,961 4,454,915 3,607,554 3,701,581 25,395,868 63,912 * 843 10,268 25,969 21,007 3,181 1,256 681 708 51,308,283 * 16,191 63,055 1,036,358 5,629,850 4,308,509 3,653,893 4,164,706 32,435,721 2,452 0 * 395 693 984 199 79 50 51 1,855,803 0 * 547 8,346 153,428 122,073 86,731 190,081 1,294,598 7,286 * 99 3,551 1,762 1,407 253 103 56 55 5,106,486 * 3,710 732,315 480,779 803,512 681,665 697,809 298,958 1,407,739 7,187 0 3,453 1,861 1,407 253 102 57 55 2,805,063 0 30,663 -24,344 364,117 277,272 369,452 243,196 1,544,707 5,264 0 1,875 1,762 1,190 236 93 54 55 2,891,736 0 3,433 26,344 249,809 218,524 128,977 249,775 2,014,875 47,140 * 296 4,646 18,373 18,221 3,018 1,212 659 716 35,349,220 * -179,507 23,391 524,211 3,361,666 2,753,111 2,319,367 2,725,133 23,821,848 68,591 1,579 13,719 26,338 20,952 3,261 1,298 703 740 46,356,191 1,243,381 715,466 2,648,858 6,449,413 4,499,373 4,135,149 3,995,745 22,668,806 68,194 1,283 13,621 26,338 20,952 3,260 1,297 703 740 41,390,365 -977,677 -165,211 42,248 5,081,047 4,070,812 3,448,586 3,541,440 26,349,121 61,781 * 690 9,084 25,372 20,670 3,237 1,287 701 739 53,443,362 * 16,133 62,176 1,034,304 5,692,618 4,390,763 3,695,749 4,319,067 34,232,552 45,414 * 296 4,251 17,778 17,699 2,911 1,171 630 679 33,750,210 * -179,507 22,844 517,562 3,253,645 2,677,712 2,263,549 2,573,651 22,620,754 64,468 1,480 11,844 25,091 20,300 3,134 1,246 672 701 43,198,827 1,239,672 637,389 2,421,385 5,946,573 4,019,841 3,620,746 3,805,852 21,507,369 64,271 1,283 11,844 25,091 20,300 3,134 1,246 672 701 39,367,893 -977,677 -171,270 105,826 4,888,119 3,958,398 3,248,478 3,418,553 24,897,467 58,814 * 690 8,097 24,223 20,078 3,116 1,240 670 700 50,972,733 * 16,133 59,817 1,012,498 5,514,764 4,245,445 3,617,316 4,135,275 32,371,486 1,726 0 * 395 595 522 107 41 29 37 1,599,009 0 * 547 6,649 108,021 75,400 55,817 151,482 1,201,094 4,123 * 99 1,875 1,247 653 127 52 31 39 3,157,364 * 3,710 78,077 227,473 502,840 479,532 514,403 189,893 1,161,437 3,923 0 1,776 1,247 653 126 51 31 39 2,022,472 0 6,058 -63,577 192,928 112,414 200,108 122,887 1,451,654 2,967 0 987 1,149 593 121 47 31 39 2,470,629 0 2,359 21,806 177,854 145,318 78,434 183,792 1,861,066 Footnotes at end of table. 283 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Footnotes at end of table. 284 Disbursements for exempt purposes Contributions, gifts, and grants paid [1] Excise tax on net investment income Total assets (book value) Number of returns Amount Number of returns Amount Number of returns Amount Number of returns Amount (16) (17) (18) (19) (20) (21) (22) (23) 73,772 1,579 15,988 27,861 22,084 3,412 1,353 735 761 40,685,960 1,163,293 1,308,821 2,557,654 5,985,205 4,110,952 3,816,961 3,594,598 18,148,475 68,591 1,579 13,719 26,338 20,952 3,261 1,298 703 740 34,932,213 1,152,071 582,638 2,198,826 5,275,714 3,632,651 3,342,844 3,148,988 15,598,482 65,583 * 690 9,874 27,011 21,885 3,351 1,317 716 739 796,416 * 164 875 14,903 91,328 68,826 54,808 65,279 500,233 79,315 569,301,990 0 0 20,722 716,834 29,473 11,178,582 22,782 61,169,773 3,463 44,995,808 1,368 40,199,547 742 43,862,038 765 367,179,409 67,135 1,480 12,929 26,149 20,768 3,169 1,254 680 706 36,728,811 1,159,583 616,414 2,249,808 5,399,311 3,618,358 3,247,667 3,352,402 17,085,268 64,468 1,480 11,844 25,091 20,300 3,134 1,246 672 701 33,850,209 1,148,362 564,577 2,127,817 5,116,990 3,372,057 2,998,501 3,083,926 15,437,979 61,544 * 690 8,788 25,352 20,911 3,174 1,249 678 701 773,648 * 164 827 14,447 87,834 66,101 53,639 61,892 488,744 71,928 527,214,678 0 0 17,072 589,631 27,612 10,346,345 21,375 56,832,318 3,208 41,517,650 1,265 37,018,207 685 40,384,849 710 340,525,679 6,637 * 99 3,058 1,712 1,316 243 99 55 55 3,957,149 * 3,710 692,407 307,846 585,894 492,593 569,295 242,196 1,063,207 4,123 * 99 1,875 1,247 653 127 52 31 39 1,082,004 * 3,709 18,061 71,009 158,724 260,594 344,343 65,062 160,502 4,040 0 1,086 1,659 974 177 68 38 38 22,769 0 47 456 3,495 2,725 1,169 3,388 11,489 7,387 0 3,650 1,861 1,407 255 103 57 55 68,591 1,579 13,719 26,338 20,952 3,261 1,298 703 740 39,038,976 1,163,293 685,732 2,351,792 5,792,875 3,951,759 3,692,331 3,478,623 17,922,572 68,591 1,579 13,719 26,338 20,952 3,261 1,298 703 740 34,932,213 1,152,071 582,638 2,198,826 5,275,714 3,632,651 3,342,844 3,148,988 15,598,482 60,010 * 690 7,999 24,858 20,574 3,204 1,271 690 723 786,967 * 164 804 14,414 88,464 66,935 53,673 64,174 498,340 67,012 550,865,674 0 0 13,719 526,451 26,338 10,043,884 20,952 56,253,663 3,261 42,307,038 1,298 38,008,303 703 41,401,002 740 362,325,334 64,468 1,480 11,844 25,091 20,300 3,134 1,246 672 701 36,589,621 1,159,583 612,808 2,237,159 5,381,645 3,589,022 3,231,420 3,315,406 17,062,578 64,468 1,480 11,844 25,091 20,300 3,134 1,246 672 701 33,850,209 1,148,362 564,577 2,127,817 5,116,990 3,372,057 2,998,501 3,083,926 15,437,979 57,436 * 690 7,308 23,709 20,022 3,110 1,234 668 695 767,783 * 164 766 14,023 85,664 64,935 52,966 61,491 487,775 62,988 519,234,486 0 0 11,844 453,476 25,091 9,441,986 20,300 54,340,042 3,134 40,548,290 1,246 36,398,535 672 39,533,666 701 338,518,492 4,123 * 99 1,875 1,247 653 127 52 31 39 2,449,355 * 3,710 72,925 114,633 411,230 362,737 460,911 163,217 859,994 4,123 * 99 1,875 1,247 653 127 52 31 39 1,082,004 * 3,709 18,061 71,009 158,724 260,594 344,343 65,062 160,502 2,574 0 * 691 1,149 552 94 37 22 28 19,184 0 * 38 392 2,800 2,000 706 2,683 10,565 4,024 0 1,875 1,247 653 127 52 31 39 42,087,312 0 127,204 832,237 4,337,455 3,478,158 3,181,339 3,477,189 26,653,730 31,631,188 0 72,975 601,898 1,913,621 1,758,747 1,609,768 1,867,336 23,806,842 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Investments in securities (book value) Total investment assets (book value) Total Government obligations Corporate stock Number of returns Amount Number of returns Amount Number of returns Amount Number of returns Amount (24) (25) (26) (27) (28) (29) (30) (31) 69,453 536,162,477 0 0 12,931 529,667 27,874 9,757,249 22,345 56,116,859 3,439 41,744,072 1,360 37,046,795 739 40,756,299 765 350,211,537 52,711 345,864,368 0 0 5,623 235,663 21,530 6,291,827 19,738 40,222,877 3,141 29,863,971 1,255 26,371,983 686 27,424,763 737 215,453,285 16,330 0 1,183 4,873 7,272 1,581 667 353 400 38,297,720 0 17,785 580,814 4,417,785 3,734,333 3,374,998 3,246,572 22,925,432 49,169 268,552,683 0 0 4,637 189,613 20,056 4,719,618 18,849 30,431,782 3,036 22,007,839 1,209 19,398,367 661 21,103,918 722 170,701,545 64,186 505,524,761 0 0 11,155 477,940 26,112 9,114,291 21,070 53,527,853 3,196 39,483,178 1,260 35,067,558 683 38,195,662 710 329,658,279 49,858 329,203,288 0 0 4,833 203,391 20,735 6,054,325 18,829 38,837,386 2,955 28,569,116 1,182 25,256,672 638 26,028,215 686 204,254,183 15,275 0 888 4,618 6,961 1,477 629 326 376 36,618,943 0 8,302 494,919 4,278,522 3,513,630 3,241,127 3,060,648 22,021,795 46,919 255,427,238 0 0 4,143 171,367 19,461 4,584,702 18,015 29,398,548 2,862 21,129,992 1,147 18,552,901 618 20,079,890 672 161,509,838 5,267 0 1,776 1,762 1,275 243 100 56 55 2,852 0 * 790 795 909 186 73 48 51 16,661,080 0 * 32,272 237,502 1,385,490 1,294,855 1,115,311 1,396,549 11,199,102 1,055 0 * 296 * 255 311 104 38 27 24 1,678,776 0 * 9,484 * 85,895 139,262 220,703 133,871 185,924 903,637 2,251 0 * 494 594 833 174 62 43 50 61,340 523,266,008 0 0 9,577 412,995 25,113 8,998,105 20,667 52,918,907 3,249 39,866,030 1,292 35,646,136 702 39,101,008 740 346,322,827 49,225 339,169,101 0 0 4,932 171,410 20,040 5,985,614 18,662 38,373,747 3,005 28,828,033 1,212 25,681,270 656 26,577,191 718 213,551,836 15,626 0 986 4,770 6,985 1,505 648 338 394 37,664,822 0 10,634 575,681 4,279,450 3,572,324 3,285,433 3,143,252 22,798,048 46,010 263,373,637 0 0 4,143 136,484 18,619 4,482,391 17,829 28,860,749 2,907 21,309,379 1,171 18,899,429 636 20,469,218 705 169,215,986 58,332 499,376,407 0 0 8,590 383,077 23,964 8,472,471 20,039 51,495,049 3,124 38,659,430 1,243 34,607,053 671 37,620,106 701 328,139,222 47,331 326,327,074 0 0 4,339 150,665 19,392 5,789,383 18,210 37,665,011 2,907 28,170,964 1,173 25,046,039 628 25,754,196 682 203,750,815 14,889 0 789 4,515 6,810 1,453 626 321 375 36,350,949 0 6,329 489,786 4,179,728 3,458,833 3,210,513 3,026,410 21,979,351 44,562 253,152,208 0 0 3,748 122,675 18,172 4,383,129 17,407 28,395,902 2,817 20,853,974 1,138 18,416,552 611 19,850,870 669 161,129,107 3,008 0 987 1,149 628 125 49 31 39 1,894 0 * 593 648 452 98 39 28 36 738 0 197 * 255 176 52 22 17 19 1,313,872 0 4,305 * 85,895 99,722 113,490 74,921 116,842 818,698 1,448 0 * 395 * 447 422 90 33 25 36 30,637,716 0 51,727 642,958 2,589,006 2,260,894 1,979,237 2,560,636 20,553,258 23,889,601 0 29,918 525,634 1,423,859 1,206,599 1,039,083 1,480,902 18,183,606 12,842,028 0 * 20,744 196,231 708,735 657,070 635,231 822,995 9,801,022 13,125,444 0 * 18,246 134,916 1,033,234 877,847 845,466 1,024,028 9,191,707 10,221,428 0 * 13,808 * 99,263 464,848 455,405 482,877 618,348 8,086,879 Footnotes at end of table. 285 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Investments in securities (book value)—continued Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Footnotes at end of table. 286 Corporate bonds Total assets (fair market value) Total investment assets (fair market value) Investments in securities (fair market value) Total Number of returns Amount Number of returns Amount Number of returns Amount Number of returns Amount (32) (33) (34) (35) (36) (37) (38) (39) 22,452 0 1,381 7,788 9,822 1,820 755 406 480 39,013,966 0 28,265 991,394 5,373,309 4,121,800 3,598,618 3,074,273 21,826,307 79,315 645,810,232 0 0 20,722 661,248 29,473 12,740,859 22,782 71,638,613 3,463 53,637,378 1,368 47,866,790 742 51,823,632 765 407,441,713 69,453 609,660,794 0 0 12,931 479,333 27,874 11,288,873 22,345 66,238,973 3,439 50,054,747 1,360 44,539,430 739 48,408,772 765 388,650,666 52,711 403,667,507 0 0 5,623 209,005 21,530 7,662,374 19,738 49,185,667 3,141 36,978,879 1,255 32,636,375 686 33,451,716 737 243,543,490 21,460 0 1,183 7,641 9,385 1,715 710 378 447 37,157,107 0 23,722 974,703 5,160,316 3,925,494 3,462,645 2,887,677 20,722,550 71,928 597,708,854 0 0 17,072 534,200 27,612 11,790,318 21,375 66,890,956 3,208 49,696,544 1,265 44,358,055 685 47,910,092 710 376,528,689 64,186 574,870,795 0 0 11,155 425,113 26,112 10,582,282 21,070 63,365,630 3,196 47,487,636 1,260 42,351,384 683 45,538,523 710 365,120,226 49,858 385,812,028 0 0 4,833 174,831 20,735 7,362,276 18,829 47,593,082 2,955 35,465,925 1,182 31,424,895 638 31,875,866 686 231,915,153 992 0 * 197 * 147 437 105 45 28 33 1,856,860 0 * 4,543 * 16,691 212,994 196,305 135,973 186,596 1,103,758 7,387 0 3,650 1,861 1,407 255 103 57 55 5,267 0 1,776 1,762 1,275 243 100 56 55 2,852 0 * 790 795 909 186 73 48 51 21,384 0 1,183 7,487 9,385 1,742 727 392 468 38,130,643 0 24,292 927,542 5,233,547 3,946,331 3,496,408 2,964,721 21,537,802 67,012 624,084,344 0 0 13,719 516,023 26,338 11,574,438 20,952 66,255,711 3,261 50,559,983 1,298 45,464,379 703 49,078,729 740 400,635,080 61,340 593,857,857 0 0 9,577 407,869 25,113 10,487,958 20,667 62,727,238 3,249 47,876,155 1,292 43,007,430 702 46,530,511 740 382,820,695 49,225 395,951,881 0 0 4,932 186,536 20,040 7,335,586 18,662 47,070,435 3,005 35,758,901 1,212 31,863,745 656 32,400,054 718 241,336,623 20,883 0 1,085 7,389 9,194 1,692 704 375 444 36,823,916 0 21,661 916,469 5,089,382 3,858,157 3,418,975 2,876,916 20,642,357 62,988 588,696,920 0 0 11,844 443,387 25,091 10,869,506 20,300 64,151,317 3,134 48,582,069 1,246 43,721,748 672 46,993,394 701 373,935,498 58,332 567,761,016 0 0 8,590 375,641 23,964 9,907,140 20,039 61,145,478 3,124 46,539,382 1,243 41,875,976 671 44,899,744 701 363,017,656 47,331 382,586,023 0 0 4,339 164,074 19,392 7,084,244 18,210 46,247,105 2,907 34,998,667 1,173 31,199,580 628 31,508,111 682 231,384,243 502 0 * 99 * 98 * 191 50 23 17 24 1,306,727 0 * 2,631 * 11,073 * 144,165 88,174 77,433 87,805 895,445 4,024 0 1,875 1,247 653 127 52 31 39 3,008 0 987 1,149 628 125 49 31 39 1,894 0 * 593 648 452 98 39 28 36 48,101,378 0 127,049 950,541 4,747,657 3,940,834 3,508,734 3,913,540 30,913,023 35,387,425 0 72,636 704,932 2,104,394 1,977,914 1,742,631 2,085,336 26,699,582 34,789,999 0 54,220 706,590 2,873,342 2,567,111 2,188,046 2,870,249 23,530,440 26,096,840 0 32,228 580,818 1,581,761 1,336,774 1,131,454 1,630,767 19,803,040 17,855,478 0 * 34,175 300,098 1,592,585 1,512,953 1,211,480 1,575,850 11,628,337 13,365,858 0 * 22,462 251,342 823,330 760,235 664,165 891,943 9,952,381 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Investments in securities (fair market value)—continued Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Government obligations Corporate stock Corporate bonds Net worth (book value) Number of returns Amount Number of returns Amount Number of returns Amount Number of returns Amount (40) (41) (42) (43) (44) (45) (46) (47) 16,330 0 1,183 4,873 7,272 1,581 667 353 400 38,717,970 0 17,817 610,654 4,456,204 3,780,047 3,421,835 3,322,005 23,109,409 49,169 325,758,946 0 0 4,637 163,226 20,056 6,033,423 18,849 39,330,142 3,036 29,013,705 1,209 25,608,023 661 27,035,023 722 198,575,404 22,452 0 1,381 7,788 9,822 1,820 755 406 480 39,190,591 0 27,963 1,018,297 5,399,321 4,185,127 3,606,517 3,094,689 21,858,677 79,295 543,696,020 0 0 20,722 533,779 29,473 10,913,615 22,767 59,855,641 3,463 43,901,283 1,365 38,882,200 742 42,418,827 763 347,190,676 15,275 0 888 4,618 6,961 1,477 629 326 376 37,036,066 0 8,341 515,769 4,319,487 3,560,036 3,286,673 3,137,692 22,208,068 46,919 311,442,394 0 0 4,143 143,276 19,461 5,845,225 18,015 38,086,554 2,862 27,918,092 1,147 24,667,229 618 25,830,363 672 188,951,655 21,460 0 1,183 7,641 9,385 1,715 710 378 447 37,333,569 0 23,213 1,001,283 5,187,041 3,987,798 3,470,994 2,907,811 20,755,429 71,909 506,214,522 0 0 17,072 414,087 27,612 10,168,952 21,360 56,052,156 3,208 40,767,248 1,263 36,164,441 685 39,247,737 708 323,399,901 1,055 0 * 296 * 255 311 104 38 27 24 1,681,905 0 * 9,475 * 94,885 136,717 220,011 135,162 184,313 901,341 2,251 0 * 494 594 833 174 62 43 50 14,316,552 0 * 19,949 188,198 1,243,588 1,095,613 940,795 1,204,659 9,623,748 992 0 * 197 * 147 437 105 45 28 33 1,857,022 0 * 4,750 * 17,015 212,280 197,329 135,523 186,878 1,103,248 7,386 0 3,650 1,861 1,407 255 102 57 55 15,626 0 986 4,770 6,985 1,505 648 338 394 38,067,505 0 10,676 605,559 4,320,860 3,618,348 3,331,001 3,199,223 22,981,836 46,010 319,579,242 0 0 4,143 151,986 18,619 5,774,428 17,829 37,488,879 2,907 28,132,306 1,171 25,029,569 636 26,215,402 705 196,786,672 21,384 0 1,183 7,487 9,385 1,742 727 392 468 38,305,134 0 23,874 955,599 5,260,695 4,008,248 3,503,175 2,985,429 21,568,115 67,007 528,404,448 0 0 13,719 356,505 26,338 9,937,434 20,952 55,540,112 3,261 41,573,038 1,295 37,094,978 703 40,369,861 738 343,532,520 14,889 0 789 4,515 6,810 1,453 626 321 375 36,750,638 0 6,372 510,674 4,223,300 3,505,135 3,256,219 3,083,918 22,165,020 44,562 308,836,922 0 0 3,748 136,460 18,172 5,629,209 17,407 36,906,576 2,817 27,573,495 1,138 24,517,242 611 25,527,691 669 188,546,250 20,883 0 1,085 7,389 9,194 1,692 704 375 444 36,998,463 0 21,243 944,361 5,117,228 3,920,038 3,426,119 2,896,502 20,672,972 62,984 499,928,679 0 0 11,844 284,181 25,091 9,342,662 20,300 53,804,098 3,134 39,898,086 1,244 35,700,508 672 38,617,089 699 322,282,056 738 0 197 * 255 176 52 22 17 19 1,316,867 0 4,305 * 94,885 97,560 113,213 74,782 115,306 816,816 1,448 0 * 395 * 447 422 90 33 25 36 502 0 * 99 * 98 * 191 50 23 17 24 1,306,672 0 * 2,631 * 11,238 * 143,467 88,210 77,056 88,927 895,142 4,023 0 1,875 1,247 653 127 51 31 39 10,742,320 0 * 15,526 * 145,219 582,303 558,811 512,327 687,711 8,240,422 37,481,498 0 119,692 744,663 3,803,485 3,134,034 2,717,759 3,171,090 23,790,775 28,475,769 0 72,325 594,772 1,736,014 1,674,952 1,394,471 1,752,772 21,250,464 Footnotes at end of table. 287 Domestic Private Foundations and Charitable Trusts: Tax Years 2005 and 2006 Statistics of Income Bulletin | Fall 2009 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 2006—Continued [All figures are estimates based on a sample—money amounts are in thousands dollars] Noncharitable-use assets Minimum investment return Distributable amount Number of returns Amount Number of returns Amount Number of returns Amount (48) (49) (50) (51) (52) (53) Type of foundation, asset size All foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-nonoperating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Grantmaking-operating foundations Total Zero or unreported $1 under $100,000 $100,000 under $1,000,000 $1,000,000 under $10,000,000 $10,000,000 under $25,000,000 $25,000,000 under $50,000,000 $50,000,000 under $100,000,000 $100,000,000 or more Footnotes at end of table. 288 79,600 * 690 20,525 29,325 22,732 3,458 1,365 740 765 536,437,710 * 416,982 799,126 11,885,968 63,504,933 47,171,147 41,909,809 44,980,061 325,769,684 78,967 * 690 20,032 29,226 22,692 3,458 1,365 739 765 26,691,923 * 20,849 39,745 586,111 3,145,672 2,348,268 2,088,442 2,241,034 16,221,802 71,018 * 690 16,086 27,205 21,185 3,201 1,262 680 708 24,809,620 * 20,685 34,872 590,029 2,931,163 2,177,755 1,963,661 2,098,851 14,992,605 72,490 * 690 17,072 27,514 21,350 3,205 1,264 684 710 508,977,586 * 416,982 716,958 11,197,492 60,770,809 44,984,869 40,191,994 42,644,361 308,054,122 71,882 * 690 16,579 27,415 21,335 3,205 1,264 683 710 25,328,194 * 20,849 35,715 551,988 3,009,711 2,239,087 2,002,692 2,124,249 15,343,902 71,018 * 690 16,086 27,205 21,185 3,201 1,262 680 708 24,809,620 * 20,685 34,872 590,029 2,931,163 2,177,755 1,963,661 2,098,851 14,992,605 7,110 0 3,453 1,811 1,382 253 101 56 55 27,460,124 0 82,168 688,476 2,734,124 2,186,279 1,717,815 2,335,700 17,715,563 7,085 0 3,453 1,811 1,356 253 101 56 55 1,363,729 0 4,029 34,123 135,961 109,181 85,749 116,785 877,900 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 67,371 * 690 13,522 26,240 20,922 3,258 1,295 703 740 525,293,421 * 416,982 692,011 11,023,462 60,642,107 45,455,787 40,808,386 43,448,011 322,806,676 67,173 * 690 13,325 26,240 20,922 3,258 1,295 703 740 26,175,076 * 20,849 34,420 548,301 3,022,651 2,267,923 2,036,465 2,169,178 16,075,291 62,928 * 690 11,450 24,885 20,159 3,131 1,244 669 699 24,603,944 * 20,685 31,303 555,907 2,869,432 2,148,076 1,952,658 2,077,032 14,948,849 63,612 * 690 11,844 25,042 20,285 3,133 1,245 672 701 504,077,598 * 416,982 643,699 10,468,513 59,120,584 44,289,825 39,906,073 42,105,075 307,126,846 63,415 * 690 11,647 25,042 20,285 3,133 1,245 672 701 25,122,383 * 20,849 32,083 520,553 2,946,575 2,209,625 1,991,491 2,102,031 15,299,177 62,928 * 690 11,450 24, [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A83975808c89ffc8f. Public record. Not legal advice.