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PHILANTHROPIC FACILITATION
ACT of 2011


The current economic recession has resulted in the coincidence of fewer
philanthropic dollars with greater philanthropic need. Accordingly, private foundations are looking for a way to generate a return, however modest, on their funds available for distribution.

The exception for program-related investments (PRIs) under Section 4944 of the Internal Revenue Code of 1986, as amended (the "Code"), allows a non-profit to make a return on an
investment which also qualifies as a qualifying distribution under Section 4942 of the Code.

The Philanthropic Facilitation Act of 2011 would improve the ability of private foundations to use the PRI exception more efficiently and thereby would open up additional capital for investment in economically-distressed industries.

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