Issue title: Administrative expenses treated as qualifying distributions for the purposes of IRC Section 4942 - Taxes on Failure to Distribute Income Description: Qualifying distributions under IRC Section 4942 include that portion of reasonable and necessary administrative expenses paid to accomplish one or more exempt purposes under IRC Sections 170(c)(1) and 170(c)(2)(B). Neither the Internal Revenue Code nor the Treasury Regulations set any limits on the amount of administrative expenses that may be used as qualifying distributions provided that the administrative expenses are reasonable and necessary for the accomplishment of the private foundation’s exempt purposes. Limitation amounts for administrative expenses under former Section 4942(g)(4) no longer apply to tax years beginning after 1990. See Pension Protection Act of 2006, Pub. L. No. 109-280, Section 1244(a), Section 1244(c). Analysis: See Technical Guide 59 Taxes on Foundation Failure to Distribute Income IRC 4942 PDF
