US private operating foundation: sourced answers
1 answer to specific questions — each with a verbatim quote from an official source and a link to it.
Every answer is checked against a verbatim quote from a stored copy of its source and has passed an independent review. This is reference information, not legal advice: rules change, and the outcome depends on your circumstances.
Legal form in a country
What minimum share of assets must the structure distribute each year
Substantially all of the lesser of adjusted net income or minimum investment return, spent directly on activities
«nments Tax exempt bonds Taxpayer identification numbers (TIN) To qualify as an operating foundation, the organization must make qualifying distributions directly for the active conduct of its exempt activities equal to substantially all (at least 85 percent) of the lesser of its: Adjusted net income , or Minimum investment return . If a private foundation's qualifying distributions exceed its minimum investment return for the tax year, but are less than its adjusted net income, substantially all of the total qualified distributions must be made directly for the active conduct of the foundat»
Source: irs.gov · source copy as of 2026-10-03
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