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Nonprofit Law/501(c)(3) Public Charity


A 501(c)(3) public organization who operates for educational purposes, Can this organization make an educational grant to a 501(c)(10) public organization for educational purposes

When a 501(c)(3) organization gives funding to an organization that is not eligible itself to receive donations that are deductible as charitable contributions for federal income tax purposes, I suggest not using the word "grant" but use the word "contract".

But, if the "educational purposes" that you refer to are the type of educational purposes that are accepted by the IRS for 501(c)(3) organizations, then the 501(c)(3) public charity may make a grant to a 501(c)(3) organization. That is because certain donations to 501(c)(10) organizations are deductible.  As we can see on page 72 of IRS Publication 557 in the last column which is entitled, "Contributions allowable", for the 501(c)(10) organizations we see, "Yes, if for certain Sec. 501(c)(3) purposes."

Harvey Mechanic, Attorney at Law -

P.S. This response is intended to be a general statement of law, should not be relied upon as legal advice and does not create an attorney/client relationship.  

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Harvey Mechanic


I am an attorney and I volunteer time to answer general questions about U.S. Federal income tax issues of nonprofit 501(c)(3) public charities only. Those questions could be about establishing and maintaining legal requirements for such non-profit organizations in the United States, including Internal Revenue service filings and requirements. I will not be working on this free forum to answer questions about Nonprofit's possible unrelated or for-profit businesses or how to fill out forms. This forum is only for general questions about federal tax law, not as the law applies to your specific situation. If you do not make your question public then I will not be spending much of my donated time on answers that would not benefit the public. If you have other questions, please contact me at I will reply from my email. In any case, do not reveal confidential information to me until after I have contracted with you to provide personal legal services. My responses on this forum are intended to be general statements of law, should not be relied upon as legal advice, and do not create an attorney/client relationship. For me to consider your individual situation and how the law applies, I would need to gather extensive information about the situation. To search my previous answers you can do a Google search by "" without the quotes and then add your search terms before hitting enter.


I have been practicing law and especially the law of nonprofit organizations since 1990 when I was admitted to the New York Bar and I have maintained my status with the Bar since that time.


B.S. Columbia University in New York City, 1970

J.D. (Law Degree) Brooklyn Law School, 1990 -- Cum Laude.

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