The foundation's full-payment period includes each tax year that begins after the end of the start-up period. The full payment period minimum amount, the amount that the foundation must actually distribute in cash or its equivalent in each tax year of the full-payment period and must be not less than 100 percent of its distributable amount, for that year, without regard to the carryover of excess qualifying distributions. However, if the foundation distributes in a tax year an amount exceeding the full-payment period minimum amount for that year, the excess reduces the full-payment period minimum amount for the five tax years immediately following the tax year in which the excess distribution is made. The excess reduces the full-payment period minimum amount in each successive tax year of the five-year period, in order, until completely used up.
